Oppenheimer & Co. Inc.
- Regulatory AUM
- $36.7B
- Discretionary
- $14.2B
- Clients
- 39,036
- Avg AUM / client
- $940K
- Accounts
- 39,036
- Employees
- 2,806
AUM over time
Annual snapshots from Form ADV filings · as of Jun 23, 2026
Asset allocation (SMA assets by investment type)
as of Jun 23, 2026Share of SMA assets by investment vehicle type, as filed in Form ADV Item 5.K. Dollar figures are percentages applied to total regulatory AUM.
Who they serve
| Client type | Clients | AUM | % of AUM |
|---|---|---|---|
| Individuals (non-high net worth) | 35,818 | $16.8B | 45.9% |
| High net worth individuals | 1,229 | $5.7B | 15.6% |
| Pension and profit sharing plans | 267 | $460M | 1.25% |
| Charitable organizations | 191 | $421M | 1.15% |
| State or municipal government entities | 1 | $94.9K | 0.0% |
| Insurance companies | 12 | $142M | 0.39% |
| Corporations and other businesses | 304 | $2.0B | 5.45% |
| Other | 1,214 | $11.1B | 30.2% |
Private funds (1)
Reported in Form ADV Section 7.B.(1), filing of Jul 2024 · $13.9M combined gross assets
| Fund | Type | Domicile | Gross assets | Owners |
|---|---|---|---|---|
| Oppenheimer Activist Partners Lp | Hedge Fund | Delaware | $13.9M | 21 |
Retirement plan clients
Plans that reported this firm as an investment service provider on Form 5500 Schedule C.
People (1,162)
roster as of Jul 20, 2026| Name | Role / title | Credentials | With firm since | Ownership |
|---|---|---|---|---|
| Lowenthal, Albert, Grinsfelder | Chmn/Dir/Ceo Owns 100% Of Phase Ii Fin'l | Oct 1985 (41y) | 75% or more of Phase Ii Financial Inc. (indirect) | |
| Robert Steven Lowenthal | Director/President | Oct 2005 (21y) | Less than 5% | |
| Mcnamara, Dennis, Patrick | E.V.P./Clo/Secretary | Jan 2006 (21y) | Less than 5% | |
| Mcguire, John Thomas | Managing Director/Deputy General Counsel Director Of Litigation | Jan 2007 (20y) | Less than 5% | |
| Benedetto, John Anthony | Director | Apr 2014 (12y) | Less than 5% | |
| Siegel, Douglas, Thornley | Chief Compliance Officer | Feb 2016 (11y) | Less than 5% | |
| Edward Patrick Harrington | Executive Vice President Private Client Services | Feb 2019 (8y) | Less than 5% | |
| Molokie Jr, Leon E | Executive Vice President Chief Operations Officer | Apr 2020 (6y) | Less than 5% | |
| Watkins, Brad, Michael | Executive Vice President Cfo | Aug 2022 (4y) | Less than 5% | |
| Brian Donald Sayers | Registered representative | Jan 2003 (24y) | ||
| George Thomas Ebenhack | Registered representative | Jan 2003 (24y) | ||
| Jackie Lea Abels | Registered representative | Jan 2003 (24y) | ||
| Jeffrey Alan Rivlin | Registered representative | Jan 2003 (24y) | ||
| John Ernest Gilchrist | Registered representative | Jan 2003 (24y) | ||
| Marcie Kaye Mayer | Registered representative | Jan 2003 (24y) | ||
| Mark William Weinberg | Registered representative | Jan 2003 (24y) | ||
| Raymond Martin Faupel | Registered representative | Jan 2003 (24y) | ||
| Robert Allen Mandell | Registered representative | CFP | Jan 2003 (24y) | |
| Rodney Frederick Nock | Registered representative | Jan 2003 (24y) | ||
| Ronald Jacob Allison | Registered representative | Jan 2003 (24y) | ||
| Sheff Daniel Olinger | Registered representative | Jan 2003 (24y) | ||
| Steven Edward Egan | Registered representative | Jan 2003 (24y) | ||
| Steven Kirk Lauterbach | Registered representative | Jan 2003 (24y) | ||
| Wim Antonius Schut | Registered representative | Jan 2003 (24y) | ||
| Marguerite Elizabeth Tomeo | Registered representative | Jan 2003 (24y) | ||
| Paul Theodore Casali | Registered representative | Jan 2003 (24y) | ||
| Randy Farzin Moshtael | Registered representative | Jun 2003 (23y) | ||
| Harold Loyd Perkins | Registered representative | Jan 2004 (23y) | ||
| Sandra Lee Bershad | Registered representative | Jan 2004 (23y) | ||
| John Robert Shelton | Registered representative | Feb 2004 (22y) | ||
| Marcia Lindsey Locher | Registered representative | Feb 2004 (22y) | ||
| Ernest Sean Mishne | Registered representative | Mar 2004 (22y) | ||
| Daniel Jason Israelite | Registered representative | Apr 2004 (22y) | ||
| John Michael Legg | Registered representative | Jul 2004 (22y) | ||
| Peter Wallace Stauffer | Registered representative | Jul 2004 (22y) | ||
| Timothy James Vega | Registered representative | Jul 2004 (22y) | ||
| Frederick Spitzer Brown | Registered representative | Jul 2004 (22y) | ||
| Yale Andrew Saltzman | Registered representative | CFA | Aug 2004 (22y) | |
| James Douglas Watt | Registered representative | Sep 2004 (22y) | ||
| Randall Funk Pearson | Registered representative | Oct 2004 (22y) | ||
| Jerome Worth Lynn | Registered representative | Oct 2004 (22y) | ||
| Jonathan Alexander Robinson | Registered representative | CFP | Oct 2004 (22y) | |
| Matthew Lee Costa | Registered representative | Jan 2005 (22y) | ||
| Howard West Kluttz | Registered representative | Jan 2005 (22y) | ||
| Michael Douglas Eitzen | Registered representative | Jan 2005 (22y) | ||
| Douglas Matthew Faupel | Registered representative | Feb 2005 (21y) | ||
| George Hillyer Connerat | Registered representative | Mar 2005 (21y) | ||
| Donna Dyke Bajaj | Registered representative | Apr 2005 (21y) | ||
| Phillip Walker Sprague | Registered representative | Apr 2005 (21y) | ||
| Joann Elizabeth Parisi | Registered representative | May 2005 (21y) | ||
| David Robert Burke | Registered representative | May 2005 (21y) | ||
| Brian Dean Hammer | Registered representative | Jul 2005 (21y) | ||
| Batia Praizner | Registered representative | Jul 2005 (21y) | ||
| E Matthew Steinberg | Registered representative | Jul 2005 (21y) | ||
| Eric David Gartland | Registered representative | Jul 2005 (21y) | ||
| Lawrence Robert Yerkees | Registered representative | Jul 2005 (21y) | ||
| Brian Joseph Walsh | Registered representative | Aug 2005 (21y) | ||
| Judith Gerette Gordon | Registered representative | Aug 2005 (21y) | ||
| Bill Michael Friedrich | Registered representative | Aug 2005 (21y) | ||
| Drake Rodney Sacks | Registered representative | CFP | Aug 2005 (21y) | |
| Regine Rigal | Registered representative | Aug 2005 (21y) | ||
| Irwin Norman Mazur | Registered representative | Aug 2005 (21y) | ||
| Walter Victor Usinowicz | Registered representative | Aug 2005 (21y) | ||
| Frank Michael Zuch | Registered representative | Aug 2005 (21y) | ||
| Anne I Chao | Registered representative | Aug 2005 (21y) | ||
| Carlos Arturo Burns | Registered representative | Aug 2005 (21y) | ||
| Kevin Charles Willett | Registered representative | Aug 2005 (21y) | ||
| Merrell Gerard Siegel | Registered representative | Aug 2005 (21y) | ||
| Nilamber Bhakta Shrestha | Registered representative | Aug 2005 (21y) | ||
| Edmond Robert Nass | Registered representative | CFA | Aug 2005 (21y) | |
| Lawrence Jay Rubinstein | Registered representative | Aug 2005 (21y) | ||
| Michael John Hoctor | Registered representative | Aug 2005 (21y) | ||
| Mark Raymond Reynolds | Registered representative | Sep 2005 (21y) | ||
| Michael Bruce Lemkin | Registered representative | Sep 2005 (21y) | ||
| Sandy Richard Lesser | Registered representative | Sep 2005 (21y) | ||
| Timothy Roger Atyeo | Registered representative | Sep 2005 (21y) | ||
| Glenn Thomas Brohman | Registered representative | Sep 2005 (21y) | ||
| Michael David Barocas | Registered representative | Sep 2005 (21y) | ||
| Frederic Jay Leonard | Registered representative | Sep 2005 (21y) | ||
| Steven David Schultz | Registered representative | Sep 2005 (21y) | ||
| James Bryon Bladel | Registered representative | Sep 2005 (21y) | ||
| Melanie S Dematto | Registered representative | Sep 2005 (21y) | ||
| William Earl Elmore | Registered representative | Sep 2005 (21y) | ||
| Bryan Keith Tudor | Registered representative | Sep 2005 (21y) | ||
| Kimberly Ann Fitzmaurice | Registered representative | Sep 2005 (21y) | ||
| Michael Ian Douglass | Registered representative | Sep 2005 (21y) | ||
| Jerald Jay Hymen | Registered representative | Oct 2005 (21y) | ||
| Jeffrey Michael Ahrens | Registered representative | Oct 2005 (21y) | ||
| Sandra Lynn Chism | Registered representative | Oct 2005 (21y) | ||
| Andrew Weiss Levy | Registered representative | Oct 2005 (21y) | ||
| Kip Damon Reagor | Registered representative | Oct 2005 (21y) | ||
| Robert Richard Walsh | Registered representative | Oct 2005 (21y) | ||
| Robert John Davis | Registered representative | Oct 2005 (21y) | ||
| Mark Alan Kirby | Registered representative | Oct 2005 (21y) | ||
| Ronald Stephen Baruch | Registered representative | Nov 2005 (21y) | ||
| John Mcqueen | Registered representative | Nov 2005 (21y) | ||
| Michael Moore Griffith | Registered representative | Nov 2005 (21y) | ||
| Jane Gingrich Doyle | Registered representative | CFP | Nov 2005 (21y) | |
| Alan Joshua Sokol | Registered representative | Nov 2005 (21y) | ||
| Cesar Augusto Hurtado | Registered representative | Dec 2005 (21y) | ||
| Robert Craig Pelham | Registered representative | Dec 2005 (21y) | ||
| Brian Connor Murphy | Registered representative | Dec 2005 (21y) | ||
| Joseph Charles Hagan | Registered representative | Jan 2006 (21y) | ||
| Sherif Mohamed Zaki | Registered representative | Jan 2006 (21y) | ||
| Craig Lyle Platt | Registered representative | Jan 2006 (21y) | ||
| Daren Michael Antley | Registered representative | Jan 2006 (21y) | ||
| Charles Edward Roden | Registered representative | Jan 2006 (21y) | ||
| Thomas Valeo | Registered representative | Jan 2006 (21y) | ||
| David Allan Bittermann | Registered representative | CFA | Jan 2006 (21y) | |
| Jerry Alfred Wolf | Registered representative | Jan 2006 (21y) | ||
| Guy Robert Presutti | Registered representative | Jan 2006 (21y) | ||
| John D Coombs | Registered representative | Jan 2006 (21y) | ||
| Daniel Johannes Stahlie | Registered representative | Jan 2006 (21y) | ||
| Marc Damon Petrognani | Registered representative | Jan 2006 (21y) | ||
| Matthew Alan Steinfeld | Registered representative | Feb 2006 (21y) | ||
| John Lawrence West | Registered representative | Feb 2006 (20y) | ||
| James George Beyloune | Registered representative | Feb 2006 (20y) | ||
| Morton S Tinkelman | Registered representative | Feb 2006 (20y) | ||
| Frederick John Weaver | Registered representative | Feb 2006 (20y) | ||
| Stephen James Connaughton | Registered representative | Feb 2006 (20y) | ||
| Mark Allan Hauser | Registered representative | Mar 2006 (20y) | ||
| Tama Helene Zaydon | Registered representative | Mar 2006 (20y) | ||
| Michael Schwartz | Registered representative | Mar 2006 (20y) | ||
| Thomas Michael Mccarthy | Registered representative | Mar 2006 (20y) | ||
| Bruce Alan Hartzmark | Registered representative | Mar 2006 (20y) | ||
| Laurence Marc Stanger | Registered representative | Mar 2006 (20y) | ||
| Mitchell Ian Hassenbein | Registered representative | Mar 2006 (20y) | ||
| Karl Peter Rozak | Registered representative | Apr 2006 (20y) | ||
| Jay Martin Spieler | Registered representative | Apr 2006 (20y) | ||
| Sherry Lynn Buhrle | Registered representative | May 2006 (20y) | ||
| Arnold Morton Taub | Registered representative | Jun 2006 (20y) | ||
| Brigid Mary Donnelly | Registered representative | Jun 2006 (20y) | ||
| Kumar Pindiprolu | Registered representative | Jun 2006 (20y) | ||
| Phillip Sparke | Registered representative | Jun 2006 (20y) | ||
| Lori Sue Koval | Registered representative | Jun 2006 (20y) | ||
| Jeffrey David Clark | Registered representative | Jun 2006 (20y) | ||
| Joshua Marc Scherer | Registered representative | Jun 2006 (20y) | ||
| David Marc Binstock | Registered representative | Jul 2006 (20y) | ||
| Eric Robert Gauster | Registered representative | Jul 2006 (20y) | ||
| Brian Keith Dube | Registered representative | Jul 2006 (20y) | ||
| Mary Jane Theresa Ryan | Registered representative | Jul 2006 (20y) | ||
| Alexander Joseph | Registered representative | Sep 2006 (20y) | ||
| John Alan Hanhauser | Registered representative | Sep 2006 (20y) | ||
| Gerald Michael Jevic | Registered representative | Sep 2006 (20y) | ||
| James E Marconis | Registered representative | Sep 2006 (20y) | ||
| Christel Denise Good | Registered representative | Oct 2006 (20y) | ||
| Serafin Paed Aquino | Registered representative | Oct 2006 (20y) | ||
| Carrie Lynn Meyer | Registered representative | Oct 2006 (20y) | ||
| Lawrence George Cohen | Registered representative | Oct 2006 (20y) | ||
| James Francis Lowe | Registered representative | Oct 2006 (20y) | ||
| James Kenneth Dziadziola | Registered representative | Oct 2006 (20y) | ||
| Michael Joseph Orourke | Registered representative | Oct 2006 (20y) | ||
| Marc Henry Fine | Registered representative | Nov 2006 (20y) | ||
| William John Scott | Registered representative | Dec 2006 (20y) | ||
| Jonathan H Dooda | Registered representative | Dec 2006 (20y) | ||
| Jeffrey M Frisch | Registered representative | CFP | Dec 2006 (20y) | |
| Debra Beilby Kalleward | Registered representative | Jan 2007 (20y) | ||
| James Allen Montmorency | Registered representative | Jan 2007 (20y) | ||
| Andrew A Westhuis | Registered representative | CFP CFA | Feb 2007 (19y) | |
| Michael Wilmer Wood | Registered representative | Feb 2007 (19y) | ||
| John Rick Kaleh | Registered representative | Mar 2007 (19y) | ||
| Justin Michael Gelbman | Registered representative | CFP | Mar 2007 (19y) | |
| Michael John Bodnar | Registered representative | Mar 2007 (19y) | ||
| Michael Jeffrey Weinstein | Registered representative | Mar 2007 (19y) | ||
| Jeffrey Paul Rancilio | Registered representative | Apr 2007 (19y) | ||
| Peter Gerald Lenane | Registered representative | Apr 2007 (19y) | ||
| John Patrick Hyland | Registered representative | Apr 2007 (19y) | ||
| Carlos Bergouignan Sotolongo | Registered representative | May 2007 (19y) | ||
| Kimberly Ellen Breslauer | Registered representative | May 2007 (19y) | ||
| Constance Palazzolo | Registered representative | May 2007 (19y) | ||
| Ralph Kevin Crovo | Registered representative | May 2007 (19y) | ||
| Gregory Baines Iglow | Registered representative | Jun 2007 (19y) | ||
| Michael Howard Rosenmayer | Registered representative | Jun 2007 (19y) | ||
| Tuyun Brian Ra | Registered representative | Jun 2007 (19y) | ||
| Christian Daniel Kosik | Registered representative | Jun 2007 (19y) | ||
| Lawrence Paul Flynn | Registered representative | Jun 2007 (19y) | ||
| William Joseph Puvogel | Registered representative | Jun 2007 (19y) | ||
| Michael Daniel Margarites | Registered representative | CFP | Jul 2007 (19y) | |
| Brian John Bittner | Registered representative | CFA | Jul 2007 (19y) | |
| Jeremy David Siegel | Registered representative | Jul 2007 (19y) | ||
| Gregory Steven White | Registered representative | Jul 2007 (19y) | ||
| Steven Philip Auerfeld | Registered representative | Jul 2007 (19y) | ||
| Raymond Lew | Registered representative | Jul 2007 (19y) | ||
| James Patrick Charron | Registered representative | Jul 2007 (19y) | ||
| Michael Joseph Ridge | Registered representative | Aug 2007 (19y) | ||
| Loren Gary Ben | Registered representative | Aug 2007 (19y) | ||
| Angelo Vincent Mazzie | Registered representative | Sep 2007 (19y) | ||
| Michael John Pallitto | Registered representative | Sep 2007 (19y) | ||
| Karen Lynn Nichols | Registered representative | Sep 2007 (19y) | ||
| Lawrence Dobrin | Registered representative | Sep 2007 (19y) | ||
| Mary Elizabeth Ward | Registered representative | CFP | Sep 2007 (19y) | |
| Richard Tyler Steinbach | Registered representative | Oct 2007 (19y) | ||
| Matthew Henry Pang | Registered representative | Oct 2007 (19y) | ||
| Daniel Seth Tacktill | Registered representative | Nov 2007 (19y) | ||
| David Howard Lazarus | Registered representative | Nov 2007 (19y) | ||
| John Charles Hexamer | Registered representative | Nov 2007 (19y) | ||
| David Staats Carey | Registered representative | Nov 2007 (19y) | ||
| Joan Jacobson Gilchrist | Registered representative | Nov 2007 (19y) | ||
| Joseph Anthony Guttilla | Registered representative | Nov 2007 (19y) | ||
| Kathleen Marie Palumbo | Registered representative | Nov 2007 (19y) | ||
| Matthew Gerhardt Kochel | Registered representative | Nov 2007 (19y) | ||
| Michael John Mccarthy | Registered representative | Nov 2007 (19y) | ||
| Paul Edward Sortal | Registered representative | Nov 2007 (19y) | ||
| Richard Douglas Levey | Registered representative | Nov 2007 (19y) | ||
| Richard James Holland | Registered representative | Nov 2007 (19y) | ||
| Richard Pierre Peloquin | Registered representative | Nov 2007 (19y) | ||
| Robert David Rosenstock | Registered representative | Nov 2007 (19y) | ||
| Robert Nelson Barnes | Registered representative | Nov 2007 (19y) | ||
| Richard O Stocke | Registered representative | Nov 2007 (19y) | ||
| David Jerome Naert | Registered representative | Nov 2007 (19y) | ||
| David Jonathon Feigeles | Registered representative | Nov 2007 (19y) | ||
| William Meinke Kuhn | Registered representative | Nov 2007 (19y) | ||
| Danny Lane Kyle | Registered representative | Nov 2007 (19y) | ||
| Darryl Jadwick Lynch | Registered representative | Nov 2007 (19y) | ||
| Douglas Sean Britney | Registered representative | Nov 2007 (19y) | ||
| Gary Lee Takacs | Registered representative | Nov 2007 (19y) | ||
| Lance Gordon Rounds | Registered representative | Nov 2007 (19y) | ||
| Lorraine Shihchun Cheng | Registered representative | Nov 2007 (19y) | ||
| Luther Dean Haugan | Registered representative | CFP | Nov 2007 (19y) | |
| Spencer Todd Nurse | Registered representative | Nov 2007 (19y) | ||
| Dorian Gonzalez | Registered representative | CFP | Nov 2007 (19y) | |
| Kenneth James Dorazio | Registered representative | Nov 2007 (19y) | ||
| Peter James Ulbrich | Registered representative | Nov 2007 (19y) | ||
| William Alexander Williams | Registered representative | Nov 2007 (19y) | ||
| James William Forsythe | Registered representative | Nov 2007 (19y) | ||
| Daniel Joseph Odell | Registered representative | Nov 2007 (19y) | ||
| Dean Mcpherson Smith | Registered representative | Nov 2007 (19y) | ||
| Courtney Scott Mygatt | Registered representative | Nov 2007 (19y) | ||
| Jorge Daniel Etinger | Registered representative | Dec 2007 (19y) | ||
| Austin Whitney Verity | Registered representative | Dec 2007 (19y) | ||
| David Francis Manderfield | Registered representative | Dec 2007 (19y) | ||
| Gregory James Miller | Registered representative | Dec 2007 (19y) | ||
| Jovo Blagoje Djurovski | Registered representative | Dec 2007 (19y) | ||
| Justin M King | Registered representative | Jan 2008 (19y) | ||
| Christopher Burke Twomey | Registered representative | Jan 2008 (19y) | ||
| Robert Maurice Haynie | Registered representative | CFP | Jan 2008 (19y) | |
| Gregory John Boettle | Registered representative | Jan 2008 (19y) | ||
| Jorge Issac Montealegre | Registered representative | Jan 2008 (19y) | ||
| Val Joseph Bianchini | Registered representative | Jan 2008 (19y) | ||
| Jimmy Keith Fletcher | Registered representative | Mar 2008 (18y) | ||
| Alan Scott Gibbs | Registered representative | Mar 2008 (18y) | ||
| David Mathes Greenberg | Registered representative | Mar 2008 (18y) | ||
| Stephen John Seremetis | Registered representative | Apr 2008 (18y) | ||
| William Jay Oppenheim | Registered representative | May 2008 (18y) | ||
| Daniel Dileo | Registered representative | Jul 2008 (18y) | ||
| Mitchell Lynne Everitt | Registered representative | Aug 2008 (18y) | ||
| Diego Fernando Gonzalez | Registered representative | Sep 2008 (18y) | ||
| Stephen John Lozan | Registered representative | Sep 2008 (18y) | ||
| Peter Hamlin Scott | Registered representative | Oct 2008 (18y) | ||
| Neil Greenspan | Registered representative | Oct 2008 (18y) | ||
| David Kaghan Schoenkin | Registered representative | Nov 2008 (18y) | ||
| Steven Aron Weil | Registered representative | Nov 2008 (18y) | ||
| Peter Charles Palumbo | Registered representative | Nov 2008 (18y) | ||
| Michael Joseph Miele | Registered representative | Dec 2008 (18y) | ||
| Peter Andre Venzara | Registered representative | Dec 2008 (18y) | ||
| Sanford Alan Haber | Registered representative | Dec 2008 (18y) | ||
| Evan W Whaley | Registered representative | Dec 2008 (18y) | ||
| Kevin Michael Broderick | Registered representative | Jan 2009 (18y) | ||
| David Herbert Seidel | Registered representative | Jan 2009 (18y) | ||
| Timothy James Shocklee | Registered representative | Mar 2009 (17y) | ||
| Clifford B Hodgman | Registered representative | Mar 2009 (17y) | ||
| Thomas Michael Glynn | Registered representative | Mar 2009 (17y) | ||
| Robert Dan Hogue | Registered representative | Mar 2009 (17y) | ||
| Nolan Neil Metzger | Registered representative | Mar 2009 (17y) | ||
| Robert C Long | Registered representative | Mar 2009 (17y) | ||
| Daniel Preston Findley | Registered representative | Mar 2009 (17y) | ||
| Frank Dominic Carpin | Registered representative | Mar 2009 (17y) | ||
| John R Rich | Registered representative | Mar 2009 (17y) | ||
| Russell Warden Good | Registered representative | CFA | Mar 2009 (17y) | |
| Steven Benny Restifo | Registered representative | Mar 2009 (17y) | ||
| Virginia Baker Saslow | Registered representative | CFP | Mar 2009 (17y) | |
| William Asbury Whitaker | Registered representative | Mar 2009 (17y) | ||
| William W Watson | Registered representative | Chartered Financial Consultant CFA | Mar 2009 (17y) | |
| Donna Sue Guerrero | Registered representative | Mar 2009 (17y) | ||
| Lori Judith Rappaport Steiner | Registered representative | Mar 2009 (17y) | ||
| Peter Paul Rembalsky | Registered representative | Mar 2009 (17y) | ||
| Victoria Vera Wolfson | Registered representative | Mar 2009 (17y) | ||
| Laurence Joseph Wulker | Registered representative | CFP | Mar 2009 (17y) | |
| Jonathan Travis Payne | Registered representative | Mar 2009 (17y) | ||
| Stephen Bernard Slewitzke | Registered representative | Mar 2009 (17y) | ||
| Teresa Carol Incao | Registered representative | Mar 2009 (17y) | ||
| Timothy Arthur Vanderver | Registered representative | Mar 2009 (17y) | ||
| Kenneth Howard Rosenbaum | Registered representative | Mar 2009 (17y) | ||
| David William Collins | Registered representative | Mar 2009 (17y) | ||
| Fred Ben Seid | Registered representative | CFP | Mar 2009 (17y) | |
| Joshua Warren Hayes | Registered representative | CFP | Apr 2009 (17y) | |
| Adam Manna Quarello | Registered representative | Apr 2009 (17y) | ||
| James Francis Comerford | Registered representative | Apr 2009 (17y) | ||
| Duane Clifton Larue | Registered representative | Apr 2009 (17y) | ||
| James Kenneth Louderbaugh | Registered representative | Apr 2009 (17y) | ||
| Alan Robert Riffle | Registered representative | Apr 2009 (17y) | ||
| Robert Ryan Wrobleske | Registered representative | Apr 2009 (17y) | ||
| Adam Ryan Jacobs | Registered representative | Apr 2009 (17y) | ||
| Craig Ernst Chapman | Registered representative | CFP | Apr 2009 (17y) | |
| Bruce Jay Lessinger | Registered representative | May 2009 (17y) | ||
| David Michael Boon | Registered representative | May 2009 (17y) | ||
| Galen John Greiner | Registered representative | May 2009 (17y) | ||
| James George Stames | Registered representative | May 2009 (17y) | ||
| Karen E Jochimsen | Registered representative | May 2009 (17y) | ||
| Cal Rains | Registered representative | May 2009 (17y) | ||
| James Heward Nicholson | Registered representative | May 2009 (17y) | ||
| Robert Paul Henshaw | Registered representative | May 2009 (17y) | ||
| James Scott Moran | Registered representative | May 2009 (17y) | ||
| Kay Lynette Barcus | Registered representative | CFP | Jun 2009 (17y) | |
| Jeffrey William Young | Registered representative | Jun 2009 (17y) | ||
| Russell Ogan | Registered representative | Jun 2009 (17y) | ||
| Jeff David Neely | Registered representative | Jun 2009 (17y) | ||
| Michael Francis Oshaughnessey | Registered representative | Jun 2009 (17y) | ||
| Michael Allen Murphy | Registered representative | Jul 2009 (17y) | ||
| Brenda Sparks Mccleerey | Registered representative | Jul 2009 (17y) | ||
| Joseph Patrick Popp | Registered representative | Jul 2009 (17y) | ||
| Tracey A Neret | Registered representative | Jul 2009 (17y) | ||
| Jill Wilson Richardson | Registered representative | Aug 2009 (17y) | ||
| James Bruce Haass | Registered representative | Aug 2009 (17y) | ||
| Steven Mark Sterner | Registered representative | Sep 2009 (17y) | ||
| William Breckenridge Anderson | Registered representative | Sep 2009 (17y) | ||
| Charles Arthur Ruttenberg | Registered representative | Sep 2009 (17y) | ||
| Stephen Sabine Marsters | Registered representative | Sep 2009 (17y) | ||
| Tanner Gray Robinson | Registered representative | CFP | Oct 2009 (17y) | |
| Ralph Milburn Jones | Registered representative | Oct 2009 (17y) | ||
| Christopher Michael Lazos | Registered representative | Oct 2009 (17y) | ||
| Susan Diane Wesselmann | Registered representative | Oct 2009 (17y) | ||
| Douglas Joseph Standish | Registered representative | Oct 2009 (17y) | ||
| Todd Christopher Brady | Registered representative | Jan 2010 (17y) | ||
| James Dalton Woodard | Registered representative | Jan 2010 (17y) | ||
| William Vincent Reepmeyer | Registered representative | Feb 2010 (16y) | ||
| Donald Peter Weidemann | Registered representative | CFP | Feb 2010 (16y) | |
| Ligia Reyes | Registered representative | Feb 2010 (16y) | ||
| Louis Aloysius Conyard | Registered representative | Feb 2010 (16y) | ||
| Bryan Joseph Carroll | Registered representative | CFP | Feb 2010 (16y) | |
| Peter James Muldowney | Registered representative | Mar 2010 (16y) | ||
| Susan Pounds Chandler | Registered representative | Mar 2010 (16y) | ||
| Betsy Jane Gootrad | Registered representative | Mar 2010 (16y) | ||
| Philip Norman Rothman | Registered representative | CFP | Apr 2010 (16y) | |
| Steven Michael Mekler | Registered representative | Apr 2010 (16y) | ||
| Michael Gordon Lachnit | Registered representative | Apr 2010 (16y) | ||
| Kevin Craig Salk | Registered representative | May 2010 (16y) | ||
| John Brian Ogden | Registered representative | Jun 2010 (16y) | ||
| James Hugh Williams | Registered representative | Jun 2010 (16y) | ||
| Albert Anthony Napolitano | Registered representative | Jul 2010 (16y) | ||
| Thomas Michael Amadio | Registered representative | Jul 2010 (16y) | ||
| Howard Alan Hirsch | Registered representative | Aug 2010 (16y) | ||
| David C Vanech | Registered representative | Aug 2010 (16y) | ||
| Francis Xavier Williams | Registered representative | Aug 2010 (16y) | ||
| Gwendolyn Jo Hueneman | Registered representative | Aug 2010 (16y) | ||
| Mary Ann Louise Micka | Registered representative | Sep 2010 (16y) | ||
| Alexander Lanzman | Registered representative | Sep 2010 (16y) | ||
| William Dean Vanech | Registered representative | Sep 2010 (16y) | ||
| Carolyn A Meske | Registered representative | Oct 2010 (16y) | ||
| Daniel Stuart Heller | Registered representative | Oct 2010 (16y) | ||
| Matthew John Healy | Registered representative | Oct 2010 (16y) | ||
| Marc Nathan Leibowitz | Registered representative | Dec 2010 (16y) | ||
| Uri Kaufthal | Registered representative | Dec 2010 (16y) | ||
| Susan L Stephens | Registered representative | Jan 2011 (16y) | ||
| Maurice Gordon Stuffmann | Registered representative | Feb 2011 (16y) | ||
| John Berton Teetsel | Registered representative | Feb 2011 (15y) | ||
| Christine M Telesco | Registered representative | Feb 2011 (15y) | ||
| Kendall Dunn Avery | Registered representative | Mar 2011 (15y) | ||
| Sheldon David Freisinger | Registered representative | Apr 2011 (15y) | ||
| Christopher Michael Audus | Registered representative | CFP | May 2011 (15y) | |
| Patrick T Catarello | Registered representative | May 2011 (15y) | ||
| Joseph Benton Steffy | Registered representative | May 2011 (15y) | ||
| Joseph James Quigley | Registered representative | Jun 2011 (15y) | ||
| Jeffrey Aaron Witt | Registered representative | Jul 2011 (15y) | ||
| Kimber Lela Woods | Registered representative | CFP | Aug 2011 (15y) | |
| Jonathan Philip Kolodkin | Registered representative | Sep 2011 (15y) | ||
| Gregory John Augustine | Registered representative | Oct 2011 (15y) | ||
| Daniel James Waskiewicz | Registered representative | Nov 2011 (15y) | ||
| James Turner Norris | Registered representative | CFP | Nov 2011 (15y) | |
| Brooke Lea Bergrud | Registered representative | Nov 2011 (15y) | ||
| Scott Shulman | Registered representative | Nov 2011 (15y) | ||
| John Blair Nicholas | Registered representative | Dec 2011 (15y) | ||
| Gustavo Andres Jaso Buzzoni | Registered representative | Dec 2011 (15y) | ||
| Laurence J Casper | Registered representative | Dec 2011 (15y) | ||
| Michael Dennis Reagan | Registered representative | Dec 2011 (15y) | ||
| Ramon E Valet | Registered representative | Jan 2012 (15y) | ||
| Jason Lee Twomey | Registered representative | Jan 2012 (15y) | ||
| Joshua Michael Kaufthal | Registered representative | Feb 2012 (14y) | ||
| Alberto Ottaviani | Registered representative | Feb 2012 (14y) | ||
| Jennifer Ann Shandler | Registered representative | Feb 2012 (14y) | ||
| David Michael France | Registered representative | Mar 2012 (14y) | ||
| Walter Alan Cooper | Registered representative | Mar 2012 (14y) | ||
| Mitchell Hal Reback | Registered representative | Apr 2012 (14y) | ||
| Susan Regina Mitchell | Registered representative | Apr 2012 (14y) | ||
| William J Kavanagh | Registered representative | Apr 2012 (14y) | ||
| Christina Leigh Simpson | Registered representative | May 2012 (14y) | ||
| Burt Barry Freedman | Registered representative | May 2012 (14y) | ||
| Yevgeny Tunitsky | Registered representative | CFP | May 2012 (14y) | |
| Sean Meier | Registered representative | Jun 2012 (14y) | ||
| Tom G Thacker | Registered representative | Jun 2012 (14y) | ||
| Christopher Mark Oconnor | Registered representative | Jul 2012 (14y) | ||
| Mandah Doo | Registered representative | Jul 2012 (14y) | ||
| Frances Annette Batista | Registered representative | Aug 2012 (14y) | ||
| Lawrence R Wilkes | Registered representative | Nov 2012 (14y) | ||
| Owen Bruce Rosenblum | Registered representative | Nov 2012 (14y) | ||
| Kristin W Marinis | Registered representative | CFP | Nov 2012 (14y) | |
| George W Fellows | Registered representative | Jan 2013 (14y) | ||
| Anthony A Pell | Registered representative | Jan 2013 (14y) | ||
| David Lee | Registered representative | Jan 2013 (14y) | ||
| Sharon Ann Young | Registered representative | Jan 2013 (14y) | ||
| Casey Smith | Registered representative | CFP | Jan 2013 (14y) | |
| Guillermo Bicas | Registered representative | Jan 2013 (14y) | ||
| H. Peter Petrosky | Registered representative | CFP | Feb 2013 (13y) | |
| Anthony Joseph Manougian | Registered representative | Feb 2013 (13y) | ||
| Clara I Montanez | Registered representative | Feb 2013 (13y) | ||
| Gerald Myron Berman | Registered representative | Feb 2013 (13y) | ||
| Steven R Baaden | Registered representative | Feb 2013 (13y) | ||
| Aren Shawn Mito | Registered representative | Feb 2013 (13y) | ||
| Caitlin R Falenski | Registered representative | CFP | Mar 2013 (13y) | |
| Raymond Lewis Dinkel | Registered representative | Apr 2013 (13y) | ||
| Kathleen Lynn Murray | Registered representative | May 2013 (13y) | ||
| Jonathan Moulton | Registered representative | May 2013 (13y) | ||
| Elizabeth Cicolello Messina | Registered representative | May 2013 (13y) | ||
| Susan Pajer | Registered representative | Jun 2013 (13y) | ||
| Eric Brian Rosenberg | Registered representative | Jun 2013 (13y) | ||
| Stella Ma Desantis | Registered representative | Jun 2013 (13y) | ||
| Mark D Abbonizio | Registered representative | Jul 2013 (13y) | ||
| Anita Marie Daguilar | Registered representative | Jul 2013 (13y) | ||
| John Anthony Meskunas | Registered representative | Jul 2013 (13y) | ||
| Steven Brent Holbrook | Registered representative | Jul 2013 (13y) | ||
| Dirk Willem Van Roon | Registered representative | Aug 2013 (13y) | ||
| David Alexander Hertl | Registered representative | Aug 2013 (13y) | ||
| Jeffrey Edward Kerbler | Registered representative | Aug 2013 (13y) | ||
| Peter Henry Wagner | Registered representative | Aug 2013 (13y) | ||
| Drew Michael Keenan | Registered representative | CFP | Sep 2013 (13y) | |
| Anthony D'ascoli | Registered representative | Sep 2013 (13y) | ||
| Andrew Seth Martin | Registered representative | Sep 2013 (13y) | ||
| Petar Alexiev Arizanov | Registered representative | CFP | Sep 2013 (13y) | |
| Charles Peter Wallace | Registered representative | Oct 2013 (13y) | ||
| Scott Edward Heidema | Registered representative | Oct 2013 (13y) | ||
| Patrick James Hudec | Registered representative | Oct 2013 (13y) | ||
| Seldon Taylor Clarke | Registered representative | Dec 2013 (13y) | ||
| George M Schwartz | Registered representative | Dec 2013 (13y) | ||
| Derek Ryan Raymond | Registered representative | Jan 2014 (13y) | ||
| James Richard Azeltine | Registered representative | Jan 2014 (13y) | ||
| Daniel James Seidel | Registered representative | Jan 2014 (13y) | ||
| Brian Christopher Kutsmeda | Registered representative | Feb 2014 (12y) | ||
| Paul J Colligan | Registered representative | Feb 2014 (12y) | ||
| Kevin Michael Doney | Registered representative | CFP | Feb 2014 (12y) | |
| Francis Salvatore Chimenti | Registered representative | CFP | Mar 2014 (12y) | |
| Eric David Gregerson | Registered representative | Apr 2014 (12y) | ||
| Juan Francisco Manteiga | Registered representative | Jun 2014 (12y) | ||
| Joseph Fusaro | Registered representative | Jul 2014 (12y) | ||
| Leonard Joseph Silvester | Registered representative | Jul 2014 (12y) | ||
| Kevin Simson Baum | Registered representative | Jul 2014 (12y) | ||
| Marcos Andres Chevallier Boutell | Registered representative | Jul 2014 (12y) | ||
| Elaine Israel | Registered representative | Aug 2014 (12y) | ||
| Julia Schnackel | Registered representative | Aug 2014 (12y) | ||
| Andrew Scott Losty | Registered representative | CFP | Sep 2014 (12y) | |
| Daniel Francis Scannell | Registered representative | Sep 2014 (12y) | ||
| Gavin Thomas Natelli | Registered representative | Sep 2014 (12y) | ||
| Kathleen Carroll King | Registered representative | Sep 2014 (12y) | ||
| Lora Elaine Carlon | Registered representative | Oct 2014 (12y) | ||
| Michael Christopher Dickstein | Registered representative | Oct 2014 (12y) | ||
| Jenny W Chan | Registered representative | Oct 2014 (12y) | ||
| Laura Lynn Thomforde | Registered representative | Nov 2014 (12y) | ||
| Rajiv Amar Hargunani | Registered representative | Nov 2014 (12y) | ||
| Mark Christopher Larsen | Registered representative | Nov 2014 (12y) | ||
| Beverly Mountain Brumbaugh | Registered representative | CFP | Dec 2014 (12y) | |
| Jake Michael Eitzen | Registered representative | Dec 2014 (12y) | ||
| Eugene Gray Smith | Registered representative | Dec 2014 (12y) | ||
| Edward Michael Kelly | Registered representative | Feb 2015 (11y) | ||
| Daniel Brendon Goggin | Registered representative | Mar 2015 (11y) | ||
| Matthew Steven Marcolina | Registered representative | Chartered Financial Consultant | Mar 2015 (11y) | |
| Luis A Garcia | Registered representative | Mar 2015 (11y) | ||
| Omri Amit | Registered representative | Apr 2015 (11y) | ||
| Christopher M Prince | Registered representative | CFP | Apr 2015 (11y) | |
| Feng Shen | Registered representative | May 2015 (11y) | ||
| David Victor Anderson | Registered representative | May 2015 (11y) | ||
| Steven Victor Sellers | Registered representative | May 2015 (11y) | ||
| Kyle Montmorency | Registered representative | CFP | Jun 2015 (11y) | |
| James Joseph Mcnamara | Registered representative | Jun 2015 (11y) | ||
| Carrie Anne Chodera | Registered representative | Jul 2015 (11y) | ||
| James Sander Ries | Registered representative | Aug 2015 (11y) | ||
| Offer Ben Tidhar | Registered representative | Aug 2015 (11y) | ||
| Nicholas Allen Hunt | Registered representative | CFP | Aug 2015 (11y) | |
| Chad Edward Allen | Registered representative | Aug 2015 (11y) | ||
| Steven Robison Stapley | Registered representative | Aug 2015 (11y) | ||
| Ari Howard Wald | Registered representative | CFA | Aug 2015 (11y) | |
| Matthew John Kennedy | Registered representative | CFA | Aug 2015 (11y) | |
| Michael Emilio Giliberto | Registered representative | CFA | Aug 2015 (11y) | |
| Jack Meyer Zahl | Registered representative | CFP | Sep 2015 (11y) | |
| Sayke Robert Reilley | Registered representative | Oct 2015 (11y) | ||
| Mathew Christopher Valentine | Registered representative | Nov 2015 (11y) | ||
| Douglas Raymond Kline | Registered representative | Nov 2015 (11y) | ||
| Stuart N Schwartz | Registered representative | Nov 2015 (11y) | ||
| Christopher Norman Knowlton | Registered representative | Nov 2015 (11y) | ||
| Ryan Patrick Charron | Registered representative | Nov 2015 (11y) | ||
| Mitchell Joseph Hickey | Registered representative | CFP | Dec 2015 (11y) | |
| Peter Petropoulos | Registered representative | Dec 2015 (11y) | ||
| Edgar Thomas Atnip | Registered representative | Dec 2015 (11y) | ||
| Patricia Grace Thompson | Registered representative | Dec 2015 (11y) | ||
| Brett Deeter | Registered representative | Dec 2015 (11y) | ||
| Frank Erwin Deeter | Registered representative | CFP | Dec 2015 (11y) | |
| Mark Edward Baniszewski | Registered representative | Dec 2015 (11y) | ||
| Kevin William Crosser | Registered representative | Dec 2015 (11y) | ||
| Thomas Dean Dudley | Registered representative | Dec 2015 (11y) | ||
| Catalina Soto Busch | Registered representative | Dec 2015 (11y) | ||
| Francis Joseph Pisano | Registered representative | Dec 2015 (11y) | ||
| Athanacia Lallas Frey | Registered representative | Dec 2015 (11y) | ||
| Alexander Morgan Smith | Registered representative | Jan 2016 (11y) | ||
| F S Masri | Registered representative | Jan 2016 (11y) | ||
| Patrick Kevin Mcfadden | Registered representative | CFP | Jan 2016 (11y) | |
| Louis Robert Miranda | Registered representative | Jan 2016 (11y) | ||
| John Hollis Ingraham | Registered representative | Feb 2016 (10y) | ||
| Terance Richard Bertrand | Registered representative | Mar 2016 (10y) | ||
| Byron Robert Swarts | Registered representative | Mar 2016 (10y) | ||
| Zachary Monroe Eitzen | Registered representative | CFP | Mar 2016 (10y) | |
| Christopher Michael Mccann | Registered representative | Mar 2016 (10y) | ||
| Arthur Alexander Caione | Registered representative | Mar 2016 (10y) | ||
| Paul Ellias Colchamiro | Registered representative | Mar 2016 (10y) | ||
| Benjamin Michael Davis | Registered representative | Mar 2016 (10y) | ||
| Duane Dominic Cabrera | Registered representative | CFP Chartered Financial Consultant | Mar 2016 (10y) | |
| Stephen Michael Tomkins | Registered representative | Apr 2016 (10y) | ||
| Dennis Andrew Baum | Registered representative | Apr 2016 (10y) | ||
| Todd Christopher Wiggins | Registered representative | May 2016 (10y) | ||
| Donna Hope Goldman | Registered representative | CFP | May 2016 (10y) | |
| Eleni Nikiforou | Registered representative | May 2016 (10y) | ||
| Kathleen Ann Lombardo | Registered representative | May 2016 (10y) | ||
| Harvey Mark Ross | Registered representative | May 2016 (10y) | ||
| Wallace Mcrae Davis | Registered representative | CFA | May 2016 (10y) | |
| Mark Edward Trafford | Registered representative | May 2016 (10y) | ||
| Michael Joseph Murdock | Registered representative | May 2016 (10y) | ||
| Brian Gerald Orr | Registered representative | Jun 2016 (10y) | ||
| Jeffrey Alan Church | Registered representative | Jun 2016 (10y) | ||
| Joslain Joseph | Registered representative | Jun 2016 (10y) | ||
| Alan B Woller | Registered representative | Jun 2016 (10y) | ||
| Kevin Tyrone Henry | Registered representative | CFP | Jun 2016 (10y) | |
| Christopher Ryan Scott | Registered representative | Jul 2016 (10y) | ||
| Kenneth Joseph Green | Registered representative | Jul 2016 (10y) | ||
| Ralph Edward Primavera | Registered representative | Jul 2016 (10y) | ||
| Larry Lazelle Harper | Registered representative | Aug 2016 (10y) | ||
| Matthew Brian Cohen | Registered representative | Aug 2016 (10y) | ||
| Jeffrey Thomas Montville | Registered representative | Aug 2016 (10y) | ||
| Dineen Hughes | Registered representative | CFP | Sep 2016 (10y) | |
| Gail F Perrymason | Registered representative | Oct 2016 (10y) | ||
| Jay Robert Schiff | Registered representative | Chartered Financial Consultant | Oct 2016 (10y) | |
| Eleni Cecelia Louvaris Barone | Registered representative | Oct 2016 (10y) | ||
| Anthony Joseph Marino | Registered representative | Oct 2016 (10y) | ||
| Michael Andrew Pfeffer | Registered representative | Oct 2016 (10y) | ||
| Jodi Lynn Madonna | Registered representative | Nov 2016 (10y) | ||
| Ximena Goni | Registered representative | Nov 2016 (10y) | ||
| William Stoddard Valentine | Registered representative | Nov 2016 (10y) | ||
| Cynthia Ann Speno | Registered representative | Nov 2016 (10y) | ||
| Amber Dawn Mccleerey | Registered representative | Nov 2016 (10y) | ||
| Peter Douglas Watt | Registered representative | Dec 2016 (10y) | ||
| Robert Edward Ternosky | Registered representative | Dec 2016 (10y) | ||
| Timothy Kelly Horan | Registered representative | CFA | Dec 2016 (10y) | |
| Josette Lee Greechan | Registered representative | CFP | Dec 2016 (10y) | |
| Henry Benoit Scheuer | Registered representative | Dec 2016 (10y) | ||
| Matthew Robert Murphy | Registered representative | Dec 2016 (10y) | ||
| Thomas Joseph Dagger | Registered representative | Dec 2016 (10y) | ||
| Jacquelyn Paige Davis | Registered representative | CFP | Jan 2017 (10y) | |
| Kevin Thomas Lynch | Registered representative | Jan 2017 (10y) | ||
| Mark Benjamin Wickard | Registered representative | Jan 2017 (10y) | ||
| Thomas Howard Tate | Registered representative | Jan 2017 (10y) | ||
| John Devlin Mann | Registered representative | Feb 2017 (9y) | ||
| Nedim Saul | Registered representative | Feb 2017 (9y) | ||
| Christina Marie Voigt | Registered representative | Feb 2017 (9y) | ||
| Dawn M Ehret | Registered representative | Feb 2017 (9y) | ||
| Bryan Thomas Vanas | Registered representative | Feb 2017 (9y) | ||
| Andrea Loughlin | Registered representative | Mar 2017 (9y) | ||
| Allen Duane O'brian | Registered representative | CFP | Mar 2017 (9y) | |
| John Anthony Stock | Registered representative | Mar 2017 (9y) | ||
| Robert Doo Jr | Registered representative | Mar 2017 (9y) | ||
| Christopher Swift Munnelly | Registered representative | Apr 2017 (9y) | ||
| Kevin Foster Friedman | Registered representative | Apr 2017 (9y) | ||
| Leda Joan Ozmen | Registered representative | Apr 2017 (9y) | ||
| Mark Joshua Roman | Registered representative | Apr 2017 (9y) | ||
| Gary Franklin Harrington | Registered representative | Apr 2017 (9y) | ||
| Brian Michael Mcdermott | Registered representative | May 2017 (9y) | ||
| Jay Richard Rowley | Registered representative | May 2017 (9y) | ||
| Nicolay Ivanov Siclunov | Registered representative | May 2017 (9y) | ||
| Brian Francis Hayes | Registered representative | May 2017 (9y) | ||
| Elisabeth Di Sorensen | Registered representative | May 2017 (9y) | ||
| James Randall White | Registered representative | Jun 2017 (9y) | ||
| Eric Andrew Lyons | Registered representative | Jun 2017 (9y) | ||
| Ralph Louis Yovane | Registered representative | Jun 2017 (9y) | ||
| Scott Allen Sobol | Registered representative | Jun 2017 (9y) | ||
| Lawrence Harkavy | Registered representative | Jun 2017 (9y) | ||
| Ralph Disomma | Registered representative | Jun 2017 (9y) | ||
| Cheryl Lynn Allan | Registered representative | Jun 2017 (9y) | ||
| Simon Andreas Oppliger | Registered representative | Jun 2017 (9y) | ||
| Nelson Mahan Kelly | Registered representative | Jul 2017 (9y) | ||
| Michael John Peloquin | Registered representative | CFP | Jul 2017 (9y) | |
| Diane Jean Lacina | Registered representative | Jul 2017 (9y) | ||
| Elizabeth Helen Bingham | Registered representative | Jul 2017 (9y) | ||
| Janet Hayes | Registered representative | Aug 2017 (9y) | ||
| Michael Tynan | Registered representative | CFP | Aug 2017 (9y) | |
| Carol Jean Mccann | Registered representative | Aug 2017 (9y) | ||
| Christopher Ian Houchins | Registered representative | Aug 2017 (9y) | ||
| Matthew George Watson | Registered representative | Sep 2017 (9y) | ||
| Marc Levin | Registered representative | Sep 2017 (9y) | ||
| Matthew Francis Wade | Registered representative | Sep 2017 (9y) | ||
| David Clyde Pickett | Registered representative | Sep 2017 (9y) | ||
| Cheree D Wright | Registered representative | Sep 2017 (9y) | ||
| Sean C Sill | Registered representative | Oct 2017 (9y) | ||
| Nicholas Bohdan Demczar | Registered representative | Oct 2017 (9y) | ||
| Gerhard Olsen | Registered representative | Oct 2017 (9y) | ||
| Kenneth Wayne Liddy | Registered representative | Oct 2017 (9y) | ||
| Tyler Preston Britton | Registered representative | Nov 2017 (9y) | ||
| Barry Lee Lacina | Registered representative | Nov 2017 (9y) | ||
| Richard Joseph Silvia | Registered representative | Nov 2017 (9y) | ||
| Jose R Jaunarena Ferrari | Registered representative | Nov 2017 (9y) | ||
| Candice Ann Lopez | Registered representative | Nov 2017 (9y) | ||
| Sherri Harrell Ryan | Registered representative | Nov 2017 (9y) | ||
| Steven Kirk Lauterbach Ii | Registered representative | Dec 2017 (9y) | ||
| John Gerard Linehan | Registered representative | Dec 2017 (9y) | ||
| Daniel Phillip Feichtner | Registered representative | Dec 2017 (9y) | ||
| Jane Smith Okulski | Registered representative | Jan 2018 (9y) | ||
| Eric Schulkin | Registered representative | CFP | Jan 2018 (9y) | |
| Gregory Paul Chinn | Registered representative | Jan 2018 (9y) | ||
| James Patrick Lowe | Registered representative | Jan 2018 (9y) | ||
| Robert C Link | Registered representative | Jan 2018 (9y) | ||
| Sandra K Newberry | Registered representative | Feb 2018 (9y) | ||
| Alan Robert Schnall | Registered representative | Feb 2018 (8y) | ||
| Mario John Kustera | Registered representative | Feb 2018 (8y) | ||
| Jonathan Charles Eklund | Registered representative | Feb 2018 (8y) | ||
| Faith Marie Smith | Registered representative | Feb 2018 (8y) | ||
| Jeffrey Scott Faunce | Registered representative | Feb 2018 (8y) | ||
| Michael Joseph Kelly | Registered representative | Mar 2018 (8y) | ||
| Luis Alberto Rosario | Registered representative | Mar 2018 (8y) | ||
| Luigi Mazza | Registered representative | Mar 2018 (8y) | ||
| Lisa Marie Simon | Registered representative | Mar 2018 (8y) | ||
| Arthur Everett Chandler | Registered representative | Mar 2018 (8y) | ||
| Brent Derron Strawn | Registered representative | Mar 2018 (8y) | ||
| Dean Williams Pickett | Registered representative | Mar 2018 (8y) | ||
| Sean Mcaneney | Registered representative | May 2018 (8y) | ||
| David Joseph Maciak | Registered representative | Jun 2018 (8y) | ||
| Tobias Emanual Timm | Registered representative | Jun 2018 (8y) | ||
| Brenda Joette Obrien | Registered representative | Jun 2018 (8y) | ||
| Robert Paul Fantozzi | Registered representative | Jun 2018 (8y) | ||
| Heather Marie Ott | Registered representative | Jun 2018 (8y) | ||
| Suzanne Dale Rismiller | Registered representative | CFP | Jun 2018 (8y) | |
| Marla Elizabeth Hart | Registered representative | Jun 2018 (8y) | ||
| James Yoo | Registered representative | Jun 2018 (8y) | ||
| Shippen Royer | Registered representative | Jun 2018 (8y) | ||
| Charles Lewis Hillis | Registered representative | CFA | Jun 2018 (8y) | |
| Mark Roger Bogert | Registered representative | Jun 2018 (8y) | ||
| Christina Lomeli | Registered representative | Jul 2018 (8y) | ||
| Michael William Napier | Registered representative | CFP | Jul 2018 (8y) | |
| Irene Anne Kosik | Registered representative | CFP | Aug 2018 (8y) | |
| Michael Alexander Smith | Registered representative | Aug 2018 (8y) | ||
| Louis Gelormino | Registered representative | CFA | Aug 2018 (8y) | |
| Kjeld Engberg | Registered representative | CFA | Aug 2018 (8y) | |
| Arthur Gerard Caione | Registered representative | CFP | Aug 2018 (8y) | |
| Christopher James Barsky | Registered representative | CFA | Aug 2018 (8y) | |
| John Daniel Friebely | Registered representative | CFA | Aug 2018 (8y) | |
| Jonathan Israel Gonshor | Registered representative | Aug 2018 (8y) | ||
| Michael Austin Locher | Registered representative | CFA | Aug 2018 (8y) | |
| Michael David Deo | Registered representative | CFA | Aug 2018 (8y) | |
| Kurt Laurence Seidman | Registered representative | Aug 2018 (8y) | ||
| Patrick Anthony Locke | Registered representative | CFA | Aug 2018 (8y) | |
| Alan Derose | Registered representative | Aug 2018 (8y) | ||
| Gregg Scott Winter | Registered representative | Aug 2018 (8y) | ||
| John Louis Meskunas | Registered representative | Sep 2018 (8y) | ||
| Micheal Corcione | Registered representative | Sep 2018 (8y) | ||
| Randy Ray Bray | Registered representative | Sep 2018 (8y) | ||
| Ian Alton Zaffino | Registered representative | CFA | Sep 2018 (8y) | |
| John David Dubois | Registered representative | Sep 2018 (8y) | ||
| Anthony Charles Ruda | Registered representative | Sep 2018 (8y) | ||
| Gregory Ryan Bjork | Registered representative | Sep 2018 (8y) | ||
| Scott Andrew Schneeberger | Registered representative | CFA | Sep 2018 (8y) | |
| Kevin Lyle Daniel | Registered representative | CFP | Sep 2018 (8y) | |
| Brian William Nagel | Registered representative | CFA | Oct 2018 (8y) | |
| Rupesh Dhinoj Parikh | Registered representative | CFA | Oct 2018 (8y) | |
| Christopher Louis Lappas | Registered representative | Oct 2018 (8y) | ||
| Rosario Gregory Vezzi | Registered representative | Oct 2018 (8y) | ||
| Larry Alan Schwartzman | Registered representative | Oct 2018 (8y) | ||
| Nicholas Richard Galli Sterling | Registered representative | CFP | Oct 2018 (8y) | |
| David Dziadziola | Registered representative | Oct 2018 (8y) | ||
| Diana Sarah Rudwilleit | Registered representative | Oct 2018 (8y) | ||
| Michael W Legaspi | Registered representative | Oct 2018 (8y) | ||
| Martin Lewis Waldman | Registered representative | Nov 2018 (8y) | ||
| Nicholas Alexander Siconolfi | Registered representative | Nov 2018 (8y) | ||
| Roger Henry Felberbaum | Registered representative | Nov 2018 (8y) | ||
| John Howard Kay | Registered representative | Nov 2018 (8y) | ||
| Melissa Ann Bowyer | Registered representative | Jan 2019 (8y) | ||
| Daniel Patrick Cavagnaro | Registered representative | Jan 2019 (8y) | ||
| Domenick Pugliese | Registered representative | Jan 2019 (8y) | ||
| Bradley Edward Phillips | Registered representative | CFA | Jan 2019 (8y) | |
| Herbert Spencer Thornton | Registered representative | Jan 2019 (8y) | ||
| Andrew T Denkler | Registered representative | CFA | Feb 2019 (7y) | |
| Stephen Gironta | Registered representative | Feb 2019 (7y) | ||
| Launa Marie Rohar | Registered representative | CFP | Feb 2019 (7y) | |
| Vjosa Mekuli | Registered representative | Feb 2019 (7y) | ||
| Sue Anna Piedra | Registered representative | Mar 2019 (7y) | ||
| Joshua Stavsky | Registered representative | Apr 2019 (7y) | ||
| Kole Henry Schleimer | Registered representative | Apr 2019 (7y) | ||
| David Howard Jarrell | Registered representative | Apr 2019 (7y) | ||
| Luke Adams | Registered representative | May 2019 (7y) | ||
| Jose Ramon De Villasante | Registered representative | May 2019 (7y) | ||
| Daniel James Schreiner | Registered representative | Jun 2019 (7y) | ||
| Thomas Emanuel Wolf | Registered representative | CFP | Jun 2019 (7y) | |
| Donna Marie Madeley | Registered representative | Jun 2019 (7y) | ||
| Gabriela Javier | Registered representative | Jul 2019 (7y) | ||
| Daniel Nicolas | Registered representative | Jul 2019 (7y) | ||
| Guillermo Jose Gonzalez | Registered representative | Jul 2019 (7y) | ||
| Michael W Holland | Registered representative | Jul 2019 (7y) | ||
| Joseph Iovino | Registered representative | Jul 2019 (7y) | ||
| Lori Darlene Bennett | Registered representative | Aug 2019 (7y) | ||
| Monica Lynn Leister | Registered representative | Aug 2019 (7y) | ||
| Antoinette Cimino | Registered representative | Aug 2019 (7y) | ||
| Sherri Lynette Brown | Registered representative | Aug 2019 (7y) | ||
| Eric Robert Bartok | Registered representative | Aug 2019 (7y) | ||
| Jaclyn Ann Bedford | Registered representative | Aug 2019 (7y) | ||
| John Lawrence Mormile | Registered representative | Aug 2019 (7y) | ||
| William Frederick Gilchrist | Registered representative | Aug 2019 (7y) | ||
| Evelyn Colon | Registered representative | Aug 2019 (7y) | ||
| Edita Raslova | Registered representative | CFA | Sep 2019 (7y) | |
| Mark Allen Frommer | Registered representative | Sep 2019 (7y) | ||
| Rhonda Richardson | Registered representative | Sep 2019 (7y) | ||
| Hiram Antonio Cortes | Registered representative | Sep 2019 (7y) | ||
| Cooper Mcrae Davis | Registered representative | Sep 2019 (7y) | ||
| Ross Michael Pollock | Registered representative | Oct 2019 (7y) | ||
| Ernest Lloyd Geohagen | Registered representative | Oct 2019 (7y) | ||
| Melinda Darlene Sung | Registered representative | CFP | Oct 2019 (7y) | |
| Paul David Babaz | Registered representative | Oct 2019 (7y) | ||
| William Forte | Registered representative | Oct 2019 (7y) | ||
| Amy Beth Decker | Registered representative | Oct 2019 (7y) | ||
| William George Godfrey | Registered representative | Oct 2019 (7y) | ||
| Joanna Antoinette Capobianco | Registered representative | Nov 2019 (7y) | ||
| Richard Ribek | Registered representative | Nov 2019 (7y) | ||
| James Richard Wall | Registered representative | CFP | Nov 2019 (7y) | |
| Jonathan D'alton Thibodeaux | Registered representative | Nov 2019 (7y) | ||
| Matthew M Carey | Registered representative | Nov 2019 (7y) | ||
| Sophia Elena Haney | Registered representative | Dec 2019 (7y) | ||
| Tyler Robert Mann | Registered representative | Dec 2019 (7y) | ||
| Sarah Elizabeth Vatier | Registered representative | Jan 2020 (7y) | ||
| Jack Edward Fay | Registered representative | Jan 2020 (7y) | ||
| Michael John Paganucci | Registered representative | Jan 2020 (7y) | ||
| Ryan Denault | Registered representative | CFP | Jan 2020 (7y) | |
| David Stuart Roth | Registered representative | Jan 2020 (7y) | ||
| Jason Huang | Registered representative | Feb 2020 (6y) | ||
| Jeremy Holden Kosh | Registered representative | Feb 2020 (6y) | ||
| Joseph Michael Caserio | Registered representative | Feb 2020 (6y) | ||
| Barry Mitchell Cash | Registered representative | Feb 2020 (6y) | ||
| John Joseph Marshall | Registered representative | Mar 2020 (6y) | ||
| Barron A Natelli | Registered representative | Mar 2020 (6y) | ||
| Christopher Joseph Estevez | Registered representative | CFP | Apr 2020 (6y) | |
| Gary Steven Domoracki | Registered representative | May 2020 (6y) | ||
| Philip Anthony Buccini | Registered representative | May 2020 (6y) | ||
| Erica A Eiler | Registered representative | CFA | Jun 2020 (6y) | |
| Steven Anthony Rodriguez | Registered representative | Jun 2020 (6y) | ||
| Brian Howard Franke | Registered representative | Jul 2020 (6y) | ||
| Cynthia Dawn Newman | Registered representative | Jul 2020 (6y) | ||
| Jason Dodd | Registered representative | Jul 2020 (6y) | ||
| Morgan Constance Newman | Registered representative | CFP | Jul 2020 (6y) | |
| Brian Edward Sacks | Registered representative | Aug 2020 (6y) | ||
| David Andrew Mcgaughey | Registered representative | CFP | Aug 2020 (6y) | |
| Christopher Padula | Registered representative | Sep 2020 (6y) | ||
| Gretchen Anne Troiano | Registered representative | Sep 2020 (6y) | ||
| John Marion Hopper | Registered representative | Sep 2020 (6y) | ||
| Ryan Peter Maksimovich | Registered representative | Oct 2020 (6y) | ||
| Samuel B Drake | Registered representative | Oct 2020 (6y) | ||
| David Darin Dellinger | Registered representative | Oct 2020 (6y) | ||
| Sandra Costa Lopes | Registered representative | Nov 2020 (6y) | ||
| Mohammad Ghaffar Khan | Registered representative | Nov 2020 (6y) | ||
| James Arthur Allen | Registered representative | CFP | Dec 2020 (6y) | |
| Hiren Patel | Registered representative | Jan 2021 (6y) | ||
| Zachary J Beyloune | Registered representative | CFA | Jan 2021 (6y) | |
| Barbara Louise Long Oley | Registered representative | Jan 2021 (6y) | ||
| Denanne Michelle Heil | Registered representative | Jan 2021 (6y) | ||
| Kelsey Elizabeth Costantini | Registered representative | Jan 2021 (6y) | ||
| Robert Patrick Mccabe | Registered representative | Jan 2021 (6y) | ||
| Ronald Thomas Ochal | Registered representative | Jan 2021 (6y) | ||
| Stephen J Heil | Registered representative | Jan 2021 (6y) | ||
| Jena Daake | Registered representative | Feb 2021 (5y) | ||
| Paul Nathan Fern | Registered representative | Feb 2021 (5y) | ||
| Alberto Castaner | Registered representative | Feb 2021 (5y) | ||
| Daniel Hernan Vatterott | Registered representative | Feb 2021 (5y) | ||
| Stacey Lynn Marino | Registered representative | CFA | Mar 2021 (5y) | |
| Mitchel Stuart Penn | Registered representative | CFA | Mar 2021 (5y) | |
| Trent Alton Birdsong | Registered representative | CFP | Mar 2021 (5y) | |
| Horacio Gomez Rabago | Registered representative | Mar 2021 (5y) | ||
| Aaron Dale Chamberlin | Registered representative | Apr 2021 (5y) | ||
| Aaron Joseph Deterding | Registered representative | CFP | Apr 2021 (5y) | |
| David James Edgar Wiese | Registered representative | Apr 2021 (5y) | ||
| Amanda Grace Adamczyk | Registered representative | Apr 2021 (5y) | ||
| Brian Alan Roth | Registered representative | Apr 2021 (5y) | ||
| Ethan Simeon Fingerer | Registered representative | Apr 2021 (5y) | ||
| James Dean Johnson | Registered representative | Apr 2021 (5y) | ||
| Jared Richard Silverman | Registered representative | Apr 2021 (5y) | ||
| Joel Eric Breiter | Registered representative | Apr 2021 (5y) | ||
| John Anthony Stoltzfus | Registered representative | Apr 2021 (5y) | ||
| Kenneth John Murphy | Registered representative | Apr 2021 (5y) | ||
| Michael Edward Doherty | Registered representative | Apr 2021 (5y) | ||
| Michael Erik Mc Murray | Registered representative | Apr 2021 (5y) | ||
| Michael Leo Campione | Registered representative | Apr 2021 (5y) | ||
| Ozan Volkan | Registered representative | Apr 2021 (5y) | ||
| Paul Raymond Nathe | Registered representative | Apr 2021 (5y) | ||
| Peter Michael Cadaret | Registered representative | Apr 2021 (5y) | ||
| Robert Sablowsky | Registered representative | Apr 2021 (5y) | ||
| Noah Emanual Timm | Registered representative | Apr 2021 (5y) | ||
| Andreina Franceschi Neff | Registered representative | Apr 2021 (5y) | ||
| Jorge Alejandro Hollander | Registered representative | Apr 2021 (5y) | ||
| Erik John Hanhauser | Registered representative | CFP | May 2021 (5y) | |
| Patrick Anthony Pereira | Registered representative | May 2021 (5y) | ||
| Daniel Bennie Berge | Registered representative | CFP | May 2021 (5y) | |
| Andrew Michienzi | Registered representative | May 2021 (5y) | ||
| Eddy Weishu Hung | Registered representative | May 2021 (5y) | ||
| James Laughlin Wiley | Registered representative | May 2021 (5y) | ||
| David Anthony Cox | Registered representative | May 2021 (5y) | ||
| Mikayla Barbara Michienzi | Registered representative | May 2021 (5y) | ||
| Spencer Berens | Registered representative | May 2021 (5y) | ||
| Anthony Michael Kology | Registered representative | May 2021 (5y) | ||
| Constantinos E Livaditis | Registered representative | May 2021 (5y) | ||
| Hugo Vincent Bartell | Registered representative | May 2021 (5y) | ||
| Robert J Daries | Registered representative | May 2021 (5y) | ||
| Madonna Sylvia Johnson | Registered representative | Jun 2021 (5y) | ||
| Matthew Walter Mcguirk | Registered representative | Jun 2021 (5y) | ||
| John Joseph Gavigan | Registered representative | Jun 2021 (5y) | ||
| Albert Michael Murad | Registered representative | Jun 2021 (5y) | ||
| James Creighton Collins | Registered representative | Jun 2021 (5y) | ||
| Joaquin Eduardo Canto | Registered representative | Jul 2021 (5y) | ||
| Aileen Cecilia Birch | Registered representative | Jul 2021 (5y) | ||
| Victor Manuel Barrionuevo | Registered representative | Jul 2021 (5y) | ||
| Lisa Lindley Raboin | Registered representative | Jul 2021 (5y) | ||
| Mariacelia Blandon | Registered representative | Jul 2021 (5y) | ||
| Paul Thomas Romanello | Registered representative | Jul 2021 (5y) | ||
| Steven Da Ching Yang | Registered representative | Jul 2021 (5y) | ||
| Marisela Blandon | Registered representative | Aug 2021 (5y) | ||
| Evelyn Rubinstein | Registered representative | Aug 2021 (5y) | ||
| Leopoldo Enrique Ferris Wallis | Registered representative | Sep 2021 (5y) | ||
| Jack Cantalin | Registered representative | Sep 2021 (5y) | ||
| Michael Javed Malik | Registered representative | Oct 2021 (5y) | ||
| Thea Renee Vunk | Registered representative | Oct 2021 (5y) | ||
| William London Reif | Registered representative | Oct 2021 (5y) | ||
| Paul A Damiba | Registered representative | Oct 2021 (5y) | ||
| William Robert Friese | Registered representative | Oct 2021 (5y) | ||
| Jane Wasserstrom | Registered representative | Oct 2021 (5y) | ||
| Farhad Noory Shaya | Registered representative | Oct 2021 (5y) | ||
| Fred Berens | Registered representative | Oct 2021 (5y) | ||
| Philip Orpheos Gullo | Registered representative | Nov 2021 (5y) | ||
| Brandon Phillips | Registered representative | Nov 2021 (5y) | ||
| Guibens Youte | Registered representative | Nov 2021 (5y) | ||
| Vasilis Kambouris | Registered representative | Nov 2021 (5y) | ||
| Phillip Edward Hall | Registered representative | Jan 2022 (5y) | ||
| Cristina Marie Gonzalez | Registered representative | Feb 2022 (5y) | ||
| Dimitri Angelo Spanos | Registered representative | Feb 2022 (4y) | ||
| Patrick Edward Doherty | Registered representative | Feb 2022 (4y) | ||
| Kevin Patrick Murphy | Registered representative | Feb 2022 (4y) | ||
| Alice Beth Leopold Benintendi | Registered representative | Mar 2022 (4y) | ||
| Roberto Sanchez | Registered representative | Mar 2022 (4y) | ||
| James Francis Stevens | Registered representative | Mar 2022 (4y) | ||
| John B Lawler | Registered representative | Mar 2022 (4y) | ||
| Paul S Clemente | Registered representative | Apr 2022 (4y) | ||
| Sebastian Ernesto Iturriaga | Registered representative | Apr 2022 (4y) | ||
| Julie Kay Petty | Registered representative | Apr 2022 (4y) | ||
| David Whitman Fleming | Registered representative | May 2022 (4y) | ||
| Elizabeth Marie Ehlen | Registered representative | May 2022 (4y) | ||
| Jon Andoni Urruzuno | Registered representative | May 2022 (4y) | ||
| Ahmad Khalil | Registered representative | May 2022 (4y) | ||
| Patrick Ryan Crowley | Registered representative | May 2022 (4y) | ||
| Sean Joseph Mcnamara | Registered representative | May 2022 (4y) | ||
| Hunter Osolin | Registered representative | May 2022 (4y) | ||
| Julia Lynn Behymer | Registered representative | May 2022 (4y) | ||
| Carol Ann Liversedge | Registered representative | May 2022 (4y) | ||
| John S Luby | Registered representative | Jun 2022 (4y) | ||
| Ariya Pejouhesh | Registered representative | Jun 2022 (4y) | ||
| Jonathan Harding Meadows | Registered representative | Jun 2022 (4y) | ||
| Linda Marie Richards | Registered representative | Jul 2022 (4y) | ||
| Carey Mitchell Blecher | Registered representative | Jul 2022 (4y) | ||
| Daniel Sullivan | Registered representative | Jul 2022 (4y) | ||
| Elena Shevchenko | Registered representative | Jul 2022 (4y) | ||
| Robert John Murphy | Registered representative | Aug 2022 (4y) | ||
| Zachary Naert | Registered representative | Aug 2022 (4y) | ||
| Louis Difrancesco | Registered representative | Sep 2022 (4y) | ||
| Wayne Zhong | Registered representative | CFA | Sep 2022 (4y) | |
| Nadia A Polack | Registered representative | Sep 2022 (4y) | ||
| Ashwin Vijay Pathare | Registered representative | Sep 2022 (4y) | ||
| Tyson Lee Bauer | Registered representative | Oct 2022 (4y) | ||
| Kevin John Furnaros | Registered representative | Oct 2022 (4y) | ||
| Margaret Anne Hunter Smith | Registered representative | Oct 2022 (4y) | ||
| Aaron Haskins Fiske | Registered representative | Oct 2022 (4y) | ||
| John E Wade | Registered representative | CFP | Oct 2022 (4y) | |
| Joshua Patrick Harness | Registered representative | Oct 2022 (4y) | ||
| Julian A Natelli | Registered representative | Nov 2022 (4y) | ||
| Aaron Christopher Maciak | Registered representative | Nov 2022 (4y) | ||
| Jared Christman | Registered representative | Nov 2022 (4y) | ||
| Brian Arthur Geltzeiler | Registered representative | Nov 2022 (4y) | ||
| Kyle Andrew Matthews | Registered representative | Nov 2022 (4y) | ||
| Reid Harrison Wolch | Registered representative | CFP | Nov 2022 (4y) | |
| Jeffrey Wolf Margolies | Registered representative | Dec 2022 (4y) | ||
| Nicola Brancato | Registered representative | Dec 2022 (4y) | ||
| Michael Jevic | Registered representative | Dec 2022 (4y) | ||
| Rachel Sydney Richwine | Registered representative | Jan 2023 (4y) | ||
| Federico M Barreto | Registered representative | Jan 2023 (4y) | ||
| Derek Scott Radulski | Registered representative | Jan 2023 (4y) | ||
| Javier Alfredo Briceno | Registered representative | Jan 2023 (4y) | ||
| Gustave John Krafve | Registered representative | Feb 2023 (3y) | ||
| Bryan Francis Blair | Registered representative | CFA | Feb 2023 (3y) | |
| Cheng Li | Registered representative | CFA | Feb 2023 (3y) | |
| Lawrence Jay Olson | Registered representative | CFA | Feb 2023 (3y) | |
| Matthew Baron Hershenhorn | Registered representative | CFA | Feb 2023 (3y) | |
| Matthew S Nirenberg | Registered representative | CFA | Feb 2023 (3y) | |
| Shaymus F Contorno | Registered representative | CFA | Feb 2023 (3y) | |
| Suraj Kalia | Registered representative | CFA | Feb 2023 (3y) | |
| Zhihua Yang | Registered representative | CFA | Feb 2023 (3y) | |
| Zhiyu Jiang | Registered representative | CFA | Feb 2023 (3y) | |
| Brian S Ocampo | Registered representative | Feb 2023 (3y) | ||
| Jed Kelly | Registered representative | Mar 2023 (3y) | ||
| Patrick Aaron Schuchard | Registered representative | CFA | Mar 2023 (3y) | |
| Craig Stephen Jantz | Registered representative | Mar 2023 (3y) | ||
| Luis Abreu | Registered representative | CFP | Mar 2023 (3y) | |
| Manda Claire Hegedus | Registered representative | Mar 2023 (3y) | ||
| Laura G Kellerman | Registered representative | Apr 2023 (3y) | ||
| Paul Thomas Tierney | Registered representative | Apr 2023 (3y) | ||
| Kyle Alexander Codey | Registered representative | CFP | May 2023 (3y) | |
| Carol Zabala Vaughn | Registered representative | May 2023 (3y) | ||
| Colin Edmund Stevens | Registered representative | May 2023 (3y) | ||
| Mark Eric Terna | Registered representative | May 2023 (3y) | ||
| Joshua Yehuda Menachem Cohen | Registered representative | May 2023 (3y) | ||
| Tyler William Pratt | Registered representative | May 2023 (3y) | ||
| Kristen E Owen | Registered representative | CFA | May 2023 (3y) | |
| Susan Jane Vitkus | Registered representative | Jun 2023 (3y) | ||
| Tatiana J Zurek | Registered representative | Jun 2023 (3y) | ||
| Adam Richard Sands | Registered representative | CFA | Jul 2023 (3y) | |
| Jacob Z Moss | Registered representative | Jul 2023 (3y) | ||
| Cynthia Anne Kelley | Registered representative | Jul 2023 (3y) | ||
| James Walter Murphy | Registered representative | Jul 2023 (3y) | ||
| Paul Arthur Laliberte | Registered representative | Jul 2023 (3y) | ||
| Jeffrey Robert Lallemand | Registered representative | Aug 2023 (3y) | ||
| Jason Lee Chabek | Registered representative | Aug 2023 (3y) | ||
| Hance Walter Smith | Registered representative | Aug 2023 (3y) | ||
| Andrew Francesco Michienzi | Registered representative | Sep 2023 (3y) | ||
| Stephanie Ann Zysk | Registered representative | Sep 2023 (3y) | ||
| Scott Tyler Odonnell | Registered representative | Sep 2023 (3y) | ||
| Maureen Livernois Klimek | Registered representative | Sep 2023 (3y) | ||
| Thomas David Avazian | Registered representative | Sep 2023 (3y) | ||
| Carter Madden | Registered representative | Oct 2023 (3y) | ||
| Maria Cristina Pejoro | Registered representative | Oct 2023 (3y) | ||
| Carlos A Guerra | Registered representative | Oct 2023 (3y) | ||
| Matthew Scott Yeisley | Registered representative | Oct 2023 (3y) | ||
| Mark Benjamin Wickard | Registered representative | Nov 2023 (3y) | ||
| Shane Fugger | Registered representative | Nov 2023 (3y) | ||
| Jon M Sanders | Registered representative | Nov 2023 (3y) | ||
| Karen Schwocho Tunnecliffe | Registered representative | Nov 2023 (3y) | ||
| Nicholas John Hall | Registered representative | Nov 2023 (3y) | ||
| Richard Frank Montaldo | Registered representative | Nov 2023 (3y) | ||
| Gregg William Whelan | Registered representative | Nov 2023 (3y) | ||
| Gerardo Pena Magana | Registered representative | Dec 2023 (3y) | ||
| David Brian Holmes | Registered representative | Dec 2023 (3y) | ||
| Margaret Ann Molloy | Registered representative | Dec 2023 (3y) | ||
| Jacob Winstanley Schmitt | Registered representative | Dec 2023 (3y) | ||
| Austin T Kline | Registered representative | Dec 2023 (3y) | ||
| Cole J Bonipart | Registered representative | CFP | Jan 2024 (3y) | |
| Audre Suzanne Robertson | Registered representative | CFP | Jan 2024 (3y) | |
| Maria Del Carmen Baez | Registered representative | Jan 2024 (3y) | ||
| Stan Howard Dreyfuss | Registered representative | Jan 2024 (3y) | ||
| Harry Essayi Yessayan | Registered representative | Feb 2024 (3y) | ||
| Stacey Marie Mcculley | Registered representative | Feb 2024 (2y) | ||
| Lance Harting | Registered representative | CFP | Feb 2024 (2y) | |
| David A Madia | Registered representative | Feb 2024 (2y) | ||
| David Greeson Moffett | Registered representative | Feb 2024 (2y) | ||
| Karim Rezqui | Registered representative | Feb 2024 (2y) | ||
| Oui Seesawat Coulson | Registered representative | CFP | Feb 2024 (2y) | |
| James Stagnaro Wohrer | Registered representative | Mar 2024 (2y) | ||
| Austin C Cornish | Registered representative | Mar 2024 (2y) | ||
| Robert Sheriff | Registered representative | Mar 2024 (2y) | ||
| Callie Mcmullen Maloney | Registered representative | Mar 2024 (2y) | ||
| Joseph James Sell | Registered representative | Mar 2024 (2y) | ||
| Sarah Quigley Morey | Registered representative | Apr 2024 (2y) | ||
| Kathryn Mies Westhuis | Registered representative | Apr 2024 (2y) | ||
| Taylor Reed | Registered representative | Apr 2024 (2y) | ||
| Elio Benvenuto | Registered representative | Apr 2024 (2y) | ||
| Kayla Marie Rice | Registered representative | Apr 2024 (2y) | ||
| Devon Brett Silber | Registered representative | Apr 2024 (2y) | ||
| Kirk Elwood Davis | Registered representative | Apr 2024 (2y) | ||
| Timothy Owen Drinkall | Registered representative | May 2024 (2y) | ||
| Elyse Sari Wels | Registered representative | May 2024 (2y) | ||
| Noah Scott Wills | Registered representative | May 2024 (2y) | ||
| Mari Katherine Grace Ambro | Registered representative | Jun 2024 (2y) | ||
| Allen Saffrahn | Registered representative | Jun 2024 (2y) | ||
| Zachary Green | Registered representative | Jun 2024 (2y) | ||
| Paul David Keller | Registered representative | Jun 2024 (2y) | ||
| James Giovanni Novello | Registered representative | Jul 2024 (2y) | ||
| Mark J. Hovanic | Registered representative | Jul 2024 (2y) | ||
| Damian John Pardo | Registered representative | Jul 2024 (2y) | ||
| Jason Andrew Betley | Registered representative | Jul 2024 (2y) | ||
| Alexandra Haass | Registered representative | Jul 2024 (2y) | ||
| Joshua Marin | Registered representative | CFA | Aug 2024 (2y) | |
| Kenneth Wong | Registered representative | CFA | Aug 2024 (2y) | |
| Lindsay Schmitt | Registered representative | Aug 2024 (2y) | ||
| Ryan J Patrie | Registered representative | Aug 2024 (2y) | ||
| Noel Gunter Pearson | Registered representative | Aug 2024 (2y) | ||
| Steven Frederick Schaefer | Registered representative | Aug 2024 (2y) | ||
| Jenny Choi | Registered representative | Sep 2024 (2y) | ||
| Peter Henning Vars | Registered representative | CFA | Sep 2024 (2y) | |
| Clayton Lee Ellis | Registered representative | Sep 2024 (2y) | ||
| Ian Thomas Bannon | Registered representative | Sep 2024 (2y) | ||
| Ronald Alan Richmond | Registered representative | Sep 2024 (2y) | ||
| Shahzeb Shaikha | Registered representative | Sep 2024 (2y) | ||
| Emilyann D Rubio | Registered representative | Sep 2024 (2y) | ||
| Xingdi Zhou | Registered representative | CFP | Oct 2024 (2y) | |
| Amber Michelle Soden | Registered representative | Oct 2024 (2y) | ||
| David Matthew Garner | Registered representative | Oct 2024 (2y) | ||
| Joseph Stein | Registered representative | Oct 2024 (2y) | ||
| John Mead Rust | Registered representative | Oct 2024 (2y) | ||
| Joseph Patrick Mc Allister | Registered representative | Oct 2024 (2y) | ||
| Hee Yang | Registered representative | Oct 2024 (2y) | ||
| Heather Stella Oliver | Registered representative | CFP | Oct 2024 (2y) | |
| Dana Marie Diserio | Registered representative | Oct 2024 (2y) | ||
| Joseph John Mamer | Registered representative | Nov 2024 (2y) | ||
| Daniel Brendan Goggin | Registered representative | Nov 2024 (2y) | ||
| Cristian Camilo Rubiano | Registered representative | Nov 2024 (2y) | ||
| Nicole Elizabeth Kracum | Registered representative | Nov 2024 (2y) | ||
| Boban Markovic | Registered representative | CFA | Nov 2024 (2y) | |
| Adam Willis | Registered representative | Nov 2024 (2y) | ||
| Jean Mondestil | Registered representative | Nov 2024 (2y) | ||
| Stephanie Danger Johnston | Registered representative | Nov 2024 (2y) | ||
| Craig A Schneider | Registered representative | Dec 2024 (2y) | ||
| Roc William Willis | Registered representative | Dec 2024 (2y) | ||
| Dylan Maziarz | Registered representative | Dec 2024 (2y) | ||
| Peter Gwynn Sackson | Registered representative | Dec 2024 (2y) | ||
| Aaron M Zirker | Registered representative | Dec 2024 (2y) | ||
| Michael Angelo Aguilar | Registered representative | Dec 2024 (2y) | ||
| Christopher Michael Smith | Registered representative | Dec 2024 (2y) | ||
| Connor Cassidy | Registered representative | Dec 2024 (2y) | ||
| Austin Gregory Geils | Registered representative | Dec 2024 (2y) | ||
| Ashley Moncada | Registered representative | Dec 2024 (2y) | ||
| Brian Benjamin | Registered representative | Jan 2025 (2y) | ||
| Claudia Carin Holm | Registered representative | Jan 2025 (2y) | ||
| Andrew Allen Koontz | Registered representative | Jan 2025 (2y) | ||
| Michael C Holahan | Registered representative | Jan 2025 (2y) | ||
| Katherine Mary Baumann | Registered representative | Feb 2025 (1y) | ||
| Nancy L Findeisen | Registered representative | Feb 2025 (1y) | ||
| Andrew H Bloom | Registered representative | Feb 2025 (1y) | ||
| Brandon D Harvey | Registered representative | Mar 2025 (1y) | ||
| Lucas Stephen Seidel | Registered representative | Mar 2025 (1y) | ||
| Boyd John Klingler | Registered representative | Mar 2025 (1y) | ||
| Paul Marinis | Registered representative | Mar 2025 (1y) | ||
| Lauren Blakeley | Registered representative | Mar 2025 (1y) | ||
| Nicholas John Novak | Registered representative | Apr 2025 (1y) | ||
| Ethan Liam Burke | Registered representative | Apr 2025 (1y) | ||
| Koltyn Joseph Schilly | Registered representative | Apr 2025 (1y) | ||
| Jake Edward Taylor | Registered representative | Apr 2025 (1y) | ||
| Thomas Francis Theodorou | Registered representative | Apr 2025 (1y) | ||
| Lisa Ann Anderson | Registered representative | Apr 2025 (1y) | ||
| Gail Ann Litchfield | Registered representative | May 2025 (1y) | ||
| Rosalia Garcia | Registered representative | May 2025 (1y) | ||
| Christine Julia Kock | Registered representative | May 2025 (1y) | ||
| Kenneth Warren Glick | Registered representative | May 2025 (1y) | ||
| Richard Cheung | Registered representative | Jun 2025 (1y) | ||
| Blake Atkin | Registered representative | Jun 2025 (1y) | ||
| Maxwell Addison Luck | Registered representative | Jun 2025 (1y) | ||
| Brian Michael Dennis | Registered representative | Jun 2025 (1y) | ||
| Mary E Mckenna | Registered representative | CFP | Jun 2025 (1y) | |
| Catherine Gale Cain | Registered representative | Jun 2025 (1y) | ||
| George Joseph Fiederlein | Registered representative | CFP | Jul 2025 (1y) | |
| Jonathan Theodore Honig | Registered representative | Jul 2025 (1y) | ||
| David Richard Wright | Registered representative | Aug 2025 (1y) | ||
| Joseph Notarfrancesco | Registered representative | Aug 2025 (1y) | ||
| Julian Bernard Kasmai | Registered representative | Aug 2025 (1y) | ||
| Reiji Christopher Kodama | Registered representative | Aug 2025 (1y) | ||
| Elina Dennis | Registered representative | Aug 2025 (1y) | ||
| Savannah Crowther | Registered representative | Aug 2025 (1y) | ||
| Ali Zafar | Registered representative | Aug 2025 (1y) | ||
| Austin Jack Pieck | Registered representative | Aug 2025 (1y) | ||
| James Cao | Registered representative | Aug 2025 (1y) | ||
| William Hudson Aiken | Registered representative | Aug 2025 (1y) | ||
| Ryan Christopher Arp | Registered representative | Sep 2025 (1y) | ||
| Aida Iris Velazquez | Registered representative | Sep 2025 (1y) | ||
| Callahan Lyons | Registered representative | Sep 2025 (1y) | ||
| William Richard Maniss | Registered representative | Sep 2025 (1y) | ||
| Timothy Adam King | Registered representative | Sep 2025 (1y) | ||
| David Mitchell Snider | Registered representative | Sep 2025 (1y) | ||
| Claire Elyse Enyeart | Registered representative | Sep 2025 (1y) | ||
| Timothy Huynh | Registered representative | Sep 2025 (1y) | ||
| Caroline Anne Hunter | Registered representative | Sep 2025 (1y) | ||
| Donald Carl Rasweiler | Registered representative | Oct 2025 (1y) | ||
| Marbelys Martinez | Registered representative | Oct 2025 (1y) | ||
| Alexander Julian Sanchez | Registered representative | Oct 2025 (1y) | ||
| Matthew Gregory Beery | Registered representative | Oct 2025 (1y) | ||
| Roger John Lofquist | Registered representative | Oct 2025 (1y) | ||
| Samuel Herek | Registered representative | Oct 2025 (1y) | ||
| Tyler Prescott Parham | Registered representative | Oct 2025 (1y) | ||
| Daniel R Krall | Registered representative | Oct 2025 (1y) | ||
| Keyton John Rizzo | Registered representative | Oct 2025 (1y) | ||
| Jared Ian Hassman | Registered representative | Oct 2025 (1y) | ||
| Paramveer Singh | Registered representative | CFA | Oct 2025 (1y) | |
| Audrey Binder | Registered representative | Nov 2025 (1y) | ||
| Laura Michelle Treanor | Registered representative | Nov 2025 (1y) | ||
| Robert Berston | Registered representative | Nov 2025 (1y) | ||
| Michael James Merrigan | Registered representative | Nov 2025 (1y) | ||
| Philip David Blaxton | Registered representative | Nov 2025 (1y) | ||
| Haley Power | Registered representative | Nov 2025 (1y) | ||
| Matthew Wukitsch | Registered representative | Nov 2025 (1y) | ||
| James Brady Mccollough | Registered representative | Nov 2025 (1y) | ||
| Zachary Tyler Visconti | Registered representative | Nov 2025 (1y) | ||
| Emily Ryklin | Registered representative | Dec 2025 (1y) | ||
| Lisa Marie Stigliano | Registered representative | Dec 2025 (1y) | ||
| Patrick Bransford | Registered representative | CFP | Dec 2025 (1y) | |
| David Hunter Robb | Registered representative | Dec 2025 (1y) | ||
| Ryan Arthur Deuel | Registered representative | Dec 2025 (1y) | ||
| Mackenzie Christine Howe | Registered representative | Dec 2025 (1y) | ||
| Roberto Valdes Rodriguez | Registered representative | CFA | Dec 2025 (1y) | |
| Ryan Anthony Watts | Registered representative | Jan 2026 (1y) | ||
| Brianna Melanie Lastra | Registered representative | Jan 2026 (1y) | ||
| Dylan Andrew Honig | Registered representative | Jan 2026 (1y) | ||
| Rickey D Bellew | Registered representative | Jan 2026 (1y) | ||
| Blake Christopher Keelean | Registered representative | Jan 2026 (1y) | ||
| Alex Kavazis | Registered representative | Jan 2026 (1y) | ||
| Cort Leo Wagenberg | Registered representative | Jan 2026 (1y) | ||
| Melissa Haua | Registered representative | Feb 2026 (0y) | ||
| Boyd Crumbaugh | Registered representative | Feb 2026 (0y) | ||
| Dane Broadie | Registered representative | CFP | Feb 2026 (0y) | |
| Kenneth David Smalley | Registered representative | CFA | Feb 2026 (0y) | |
| Justin Tao | Registered representative | Mar 2026 (0y) | ||
| Michael Alexander Fernandez Ravelo | Registered representative | Mar 2026 (0y) | ||
| Caitlyn Berry | Registered representative | Mar 2026 (0y) | ||
| Justin Ramey | Registered representative | Mar 2026 (0y) | ||
| Arlette Pol | Registered representative | Mar 2026 (0y) | ||
| Leonard James Scandariato | Registered representative | Mar 2026 (0y) | ||
| Michael Tartaglia | Registered representative | CFP | Mar 2026 (0y) | |
| Carson Patrick Mccusker | Registered representative | Mar 2026 (0y) | ||
| Emily Miyoko Gemeinhardt | Registered representative | Mar 2026 (0y) | ||
| William Anders Forslund | Registered representative | Mar 2026 (0y) | ||
| Antonio Russo | Registered representative | Mar 2026 (0y) | ||
| Margaret Ann Slattery | Registered representative | Mar 2026 (0y) | ||
| Andrew Stein | Registered representative | Mar 2026 (0y) | ||
| Diana Sol | Registered representative | Mar 2026 (0y) | ||
| Nicholas Lang Nussbaumer | Registered representative | Mar 2026 (0y) | ||
| Spencer Christopher Larsen | Registered representative | Mar 2026 (0y) | ||
| Evan James Ackermann | Registered representative | Apr 2026 (0y) | ||
| Ron L Guidi | Registered representative | Apr 2026 (0y) | ||
| Ian Alexander Yi Diatlova | Registered representative | Apr 2026 (0y) | ||
| Daniel L. Erben | Registered representative | Apr 2026 (0y) | ||
| Brayden Craig Makar | Registered representative | Apr 2026 (0y) | ||
| Thomas Suckow | Registered representative | Apr 2026 (0y) | ||
| Joseph Salerno | Registered representative | Apr 2026 (0y) | ||
| Charlotte Rose Macgregor Sigg | Registered representative | Apr 2026 (0y) | ||
| Theodore Douglas Cronin | Registered representative | Apr 2026 (0y) | ||
| Edward Allan Boll | Registered representative | Apr 2026 (0y) | ||
| Joseph Alexander Waris | Registered representative | May 2026 (0y) | ||
| Karen Dalmau | Registered representative | May 2026 (0y) | ||
| Brett Hyman | Registered representative | May 2026 (0y) | ||
| Michael William Kenney | Registered representative | May 2026 (0y) | ||
| Lennon Kane Fregien Miller | Registered representative | May 2026 (0y) | ||
| Hollis Lynn Herman | Registered representative | May 2026 (0y) | ||
| Charlie Edward Santos | Registered representative | May 2026 (0y) | ||
| Bradley S Pottorf | Registered representative | May 2026 (0y) | ||
| Justin Robert Wright | Registered representative | May 2026 (0y) | ||
| Robert Pasquale Ragusa | Registered representative | Jun 2026 (0y) | ||
| Albert Christopher Nassar | Registered representative | Jun 2026 (0y) | ||
| Patrick Alano | Registered representative | Jun 2026 (0y) | ||
| Huston Lorenzo | Registered representative | Jun 2026 (0y) | ||
| Kristoffer Manaloto Sun | Registered representative | Jun 2026 (0y) | ||
| Gael Cataldo | Registered representative | Jun 2026 (0y) | ||
| Brian John Delany | Registered representative | Jun 2026 (0y) | ||
| Carter T Walsh | Registered representative | Jun 2026 (0y) | ||
| Motaz Ashri | Registered representative | Jun 2026 (0y) | ||
| Timothy James Wong | Registered representative | Jun 2026 (0y) | ||
| Marianella Armijos | Registered representative | Jun 2026 (0y) | ||
| Diana Diaz | Registered representative | Jun 2026 (0y) | ||
| Henry Thomas Nagel | Registered representative | Jun 2026 (0y) | ||
| John Joseph Alogna | Registered representative | Jun 2026 (0y) | ||
| Joel Berry | Registered representative | Jul 2026 (0y) | ||
| Paul Range | Registered representative | Jul 2026 (0y) | ||
| Christopher Ryan Bell | Registered representative | CFA | Jul 2026 (0y) | |
| Pablo Vicente Pico | Registered representative | Jul 2026 (0y) | ||
| Sarah Ashton Ennis | Registered representative | Jul 2026 (0y) |
Entity owners (Schedule A/B)
| Entity | Title / status | Since | Sch. | Ownership |
|---|---|---|---|---|
| Viner Finance Inc. | Parent Co. | Oct 1983 | A | 75% or more |
| Phase Ii Financial Inc. | Owns Class B Voting Stock Of Oppenheimer Holdings. | Oct 1985 | B | 75% or more of Oppenheimer Holdings (indirect) |
| Oppenheimer Holdings Inc. | Common Stock | Oct 1983 | B | ≈ 42.19% – 100% via E.A. Viner International Co. |
| E.A. Viner International Co. | Holding Co. | Oct 1983 | B | ≈ 56.25% – 100% via Viner Finance Inc. |
Undisclosed: 0% – 25% of the firm is not attributable from the filed Schedule A bands.
Estimated effective ownership (look-through of filed bands):
- Oppenheimer Holdings Inc.: 75% – 100% of E.A. Viner International Co. × 75% – 100% of Viner Finance Inc. × 75% – 100% direct ≈ 42.19% – 100% of the firm
- E.A. Viner International Co.: 75% – 100% of Viner Finance Inc. × 75% – 100% direct ≈ 56.25% – 100% of the firm
Roster from the IAPD representatives feed; ownership and acquisition dates from Form ADV Schedule A/B. "Since" is the earliest filed registration or acquisition date.
Private funds (1, $13.9M gross assets)
| Fund | Type | Gross assets | Min. investment | Owners |
|---|---|---|---|---|
| Oppenheimer Activist Partners Lp | Hedge Fund | $13.9M | $100K | 21 |
From Form ADV Section 7.B private fund reporting.
Retirement plans served (55)
| Plan | Sponsor | Participants | Plan assets | As of |
|---|---|---|---|---|
| El Proyecto Del Barrio 403(b) Plan | El Proyecto Del Barrio, Inc. | 489 | $14.4M | 10/01/2024 |
| Chicago Family Health Center, Inc. Employees Savings Trust | Chicago Family Health Center, Inc. | 90 | $10.3M | 07/01/2024 |
| Sycamore Services 401(k) Plan | Sycamore Services, Inc | 436 | $5.3M | 07/01/2024 |
| Kelc 401(k) Savings Plan | Kaplan Early Learning Company | 1,189 | $37.8M | 02/01/2024 |
| Strait And Lamp Lumber Company, Inc. 401(k) Profit Sharing Plan | Strait And Lamp Lumber Company, Inc | 207 | $12.6M | 01/01/2024 |
| Metro Imaging, Llc Retirement Plan | Metro Imaging, Llc | 85 | $15.7M | 01/01/2024 |
| Pipefitters Lu No. 195 Defined Contribution Plan | Board Of Trustees Pipefitters Lu No 195 Defined Contribution Plan | 260 | $6.8M | 01/01/2024 |
| Rxp Agency, Llc 401(k) Plan | Rxp Agency, Llc | 138 | $1.6M | 01/01/2024 |
| Costello, Inc. 401(k) Plan | Costello, Inc. | 0 | $0 | 01/01/2024 |
| Dignified Home Loans Llc 401(k) Profit Sharing Plan | Dignified Home Loans, Llc | 74 | $7.6M | 01/01/2024 |
| Home Franchise Concepts Retirement Savings Plan | Home Franchise Concepts, Llc | 258 | $19.4M | 01/01/2024 |
| Callsource 401(k) Plan | Callsource | 118 | $7.4M | 01/01/2024 |
| Southwestern Industries, Inc. 401(k) Plan | Southwestern Industries, Inc. | 162 | $26.4M | 01/01/2024 |
| Molecular Templates, Inc. 401(k) Plan | Molecular Templates, Inc. | 0 | $18.8M | 01/01/2024 |
| Skydance Productions, Llc 401(k) Profit Sharing Plan | Skydance Productions, Llc | 415 | $30.1M | 01/01/2024 |
| E Times Corporation 401(k) Plan | E Times Corporation | 101 | $49.7M | 01/01/2024 |
| Pindler & Pindler, Inc. Employees' Profit Sharing Plan | Pindler & Pindler, Inc. | 122 | $16.2M | 01/01/2024 |
| The Instantwhip Companies Profit Sharing Plan | Instantwhip Foods, Inc. | 281 | $23.4M | 01/01/2024 |
| Compsych Management Corporation Retirement Plan | Compsych Management Corporation | 1,414 | $53.6M | 01/01/2024 |
| Argano, Llc 401(k) Plan | Argano, Llc | 894 | $123M | 01/01/2024 |
| Chs Employee Group, Llc 401(k) Retirement Plan | Chs Employee Group, Llc | 1,801 | $100M | 01/01/2024 |
| Pyxus International, Inc. Savings And Profit Sharing Plan | Pyxus International, Inc. | 382 | $69.1M | 01/01/2024 |
| Covenant Health 401(k) Plan | Covenant Health | 9,723 | $894M | 01/01/2024 |
| The Mcgregor Retirement Savings Plan | The Mcgregor Foundation | 521 | $8.2M | 01/01/2024 |
| Faurecia Usa Holdings, Inc. Union Retirement Savings Plan | Faurecia Usa Holdings, Inc. | 3,037 | $70.3M | 01/01/2024 |
Top 25 of 55 plans by assets.
From Form 5500 service-provider disclosures.
Documents (1 archived)
| Form | Period | Size | |
|---|---|---|---|
| Form ADV (full filing) | 06/23/2026 | 7.31 MB | View · PDF · Source ↗ |
Archived copies of the firm's regulatory filings, versioned by content hash.
Disciplinary disclosures
Allegations: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION"), FOR ITS COMPLAINT AGAINST OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR "DEFENDANT"), ALLEGES THAT THIS ACTION CONCERNS OPPENHEIMER'S REPEATED FAILURES TO COMPLY WITH THE REQUIREMENTS OF THE "LIMITED OFFERING EXEMPTION," WHICH EXEMPTS CERTAIN "LIMITED OFFERINGS" OF MUNICIPAL SECURITIES FROM THE GENERAL REQUIREMENT TO PROVIDE DISCLOSURES TO INVESTORS. THE LIMITED OFFERING EXEMPTION REQUIRES, AMONG OTHER THINGS, THAT UNDERWRITERS LIKE OPPENHEIMER HAVE A REASONABLE BELIEF THAT THE MUNICIPAL SECURITIES ARE BEING SOLD ONLY TO SOPHISTICATED INVESTORS THAT ARE EACH BUYING THE SECURITIES FOR A SINGLE ACCOUNT WITHOUT A PLAN TO DISTRIBUTE THEM. YET, FROM JUNE 15, 2017 THROUGH APRIL 27, 2022 (THE "RELEVANT PERIOD"), OPPENHEIMER SOLD SECURITIES IN AT LEAST 354 MUNICIPAL OFFERINGS IN PURPORTED RELIANCE ON THE LIMITED OFFERING EXEMPTION WHEN IT HAD NOT SATISFIED THE EXEMPTION REQUIREMENTS ("VIOLATIVE OFFERINGS"). IN EACH VIOLATIVE OFFERING, OPPENHEIMER SOLD MUNICIPAL SECURITIES TO BROKER-DEALERS AND/OR INVESTMENT ADVISERS WHEN OPPENHEIMER DID NOT HAVE A REASONABLE BELIEF THAT THOSE ENTITIES WERE BUYING FOR THEIR OWN ACCOUNTS. IN FACT, OPPENHEIMER KNEW OR SHOULD HAVE KNOWN THOSE ENTITIES MAY HAVE BEEN BUYING THE SECURITIES ON BEHALF OF THEIR CUSTOMER AND/OR CLIENT ACCOUNTS. DESPITE THIS, OPPENHEIMER MADE NO INQUIRY TO DETERMINE IF THOSE ENTITIES WERE BUYING ON BEHALF OF THEIR CUSTOMERS AND/OR CLIENTS AND, IF SO, WHETHER SUCH INVESTORS MET THE EXEMPTION CRITERIA. THUS, OPPENHEIMER FAILED TO SATISFY THE LIMITED OFFERING EXEMPTION BECAUSE IT SOLD THE MUNICIPAL SECURITIES WITHOUT A REASONABLE BELIEF THAT THE BROKER-DEALERS AND/OR INVESTMENT ADVISERS, OR ANY CUSTOMERS AND/OR CLIENTS ON WHOSE BEHALF THEY MAY HAVE BEEN BUYING, WERE BOTH SOPHISTICATED AND BUYING THE SECURITIES FOR A SINGLE ACCOUNT. THROUGHOUT THE RELEVANT PERIOD, OPPENHEIMER LACKED POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT COMPLIED WITH THE LIMITED OFFERING EXEMPTION WHEN ACTING AS UNDERWRITER IN LIMITED OFFERINGS OF MUNICIPAL SECURITIES. AT THE SAME TIME, OPPENHEIMER MADE DECEPTIVE STATEMENTS TO MUNICIPAL SECURITIES ISSUERS BY REPRESENTING THAT IT WOULD AND DID COMPLY WITH THE LIMITED OFFERING EXEMPTION REQUIREMENTS. OPPENHEIMER WAS NEGLIGENT IN MAKING THESE STATEMENTS BECAUSE ITS REGULAR PRACTICE WAS TO NOT OBTAIN THE INFORMATION NECESSARY TO KNOW WHETHER ITS SALES OF MUNICIPAL SECURITIES WOULD OR DID MEET THE LIMITED OFFERING EXEMPTION REQUIREMENTS. THE 354 VIOLATIVE OFFERINGS THAT OPPENHEIMER CONDUCTED DID NOT MEET THE LIMITED OFFERING EXEMPTION REQUIREMENTS, AND OPPENHEIMER KNEW OR SHOULD HAVE KNOWN ITS STATEMENTS TO THE CONTRARY WERE DECEPTIVE. IN CONNECTION WITH THE 354 VIOLATIVE OFFERINGS IT CONDUCTED, OPPENHEIMER REALIZED AT LEAST $1,938,580 IN NET PROFITS. UPON INFORMATION AND BELIEF, OPPENHEIMER CONTINUES TO UNDERWRITE WHAT IT PURPORTS TO BE LIMITED OFFERINGS OF NEW ISSUE MUNICIPAL SECURITIES WITHOUT SATISFYING THE LIMITED OFFERING EXEMPTION REQUIREMENTS. UPON INFORMATION AND BELIEF, OPPENHEIMER HAS ALSO FAILED TO IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE LIMITED OFFERING EXEMPTION. ACCORDINGLY, OPPENHEIMER VIOLATED EXCHANGE ACT RULE 15C2-12, MSRB RULE G-27, MSRB RULE G-17, AND EXCHANGE ACT SECTION 15B(C)(1). Status: Pending Summary: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION"), FOR ITS COMPLAINT AGAINST OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR "DEFENDANT"), ALLEGES THAT THIS ACTION CONCERNS OPPENHEIMER'S REPEATED FAILURES TO COMPLY WITH THE REQUIREMENTS OF THE "LIMITED OFFERING EXEMPTION," WHICH EXEMPTS CERTAIN "LIMITED OFFERINGS" OF MUNICIPAL SECURITIES FROM THE GENERAL REQUIREMENT TO PROVIDE DISCLOSURES TO INVESTORS. THE LIMITED OFFERING EXEMPTION REQUIRES, AMONG OTHER THINGS, THAT UNDERWRITERS LIKE OPPENHEIMER HAVE A REASONABLE BELIEF THAT THE MUNICIPAL SECURITIES ARE BEING SOLD ONLY TO SOPHISTICATED INVESTORS THAT ARE EACH BUYING THE SECURITIES FOR A SINGLE ACCOUNT WITHOUT A PLAN TO DISTRIBUTE THEM. YET, FROM JUNE 15, 2017 THROUGH APRIL 27, 2022 (THE "RELEVANT PERIOD"), OPPENHEIMER SOLD SECURITIES IN AT LEAST 354 MUNICIPAL OFFERINGS IN PURPORTED RELIANCE ON THE LIMITED OFFERING EXEMPTION WHEN IT HAD NOT SATISFIED THE EXEMPTION REQUIREMENTS ("VIOLATIVE OFFERINGS"). IN EACH VIOLATIVE OFFERING, OPPENHEIMER SOLD MUNICIPAL SECURITIES TO BROKER-DEALERS AND/OR INVESTMENT ADVISERS WHEN OPPENHEIMER DID NOT HAVE A REASONABLE BELIEF THAT THOSE ENTITIES WERE BUYING FOR THEIR OWN ACCOUNTS. IN FACT, OPPENHEIMER KNEW OR SHOULD HAVE KNOWN THOSE ENTITIES MAY HAVE BEEN BUYING THE SECURITIES ON BEHALF OF THEIR CUSTOMER AND/OR CLIENT ACCOUNTS. DESPITE THIS, OPPENHEIMER MADE NO INQUIRY TO DETERMINE IF THOSE ENTITIES WERE BUYING ON BEHALF OF THEIR CUSTOMERS AND/OR CLIENTS AND, IF SO, WHETHER SUCH INVESTORS MET THE EXEMPTION CRITERIA. THUS, OPPENHEIMER FAILED TO SATISFY THE LIMITED OFFERING EXEMPTION BECAUSE IT SOLD THE MUNICIPAL SECURITIES WITHOUT A REASONABLE BELIEF THAT THE BROKER-DEALERS AND/OR INVESTMENT ADVISERS, OR ANY CUSTOMERS AND/OR CLIENTS ON WHOSE BEHALF THEY MAY HAVE BEEN BUYING, WERE BOTH SOPHISTICATED AND BUYING THE SECURITIES FOR A SINGLE ACCOUNT. THROUGHOUT THE RELEVANT PERIOD, OPPENHEIMER LACKED POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT COMPLIED WITH THE LIMITED OFFERING EXEMPTION WHEN ACTING AS UNDERWRITER IN LIMITED OFFERINGS OF MUNICIPAL SECURITIES. AT THE SAME TIME, OPPENHEIMER MADE DECEPTIVE STATEMENTS TO MUNICIPAL SECURITIES ISSUERS BY REPRESENTING THAT IT WOULD AND DID COMPLY WITH THE LIMITED OFFERING EXEMPTION REQUIREMENTS. OPPENHEIMER WAS NEGLIGENT IN MAKING THESE STATEMENTS BECAUSE ITS REGULAR PRACTICE WAS TO NOT OBTAIN THE INFORMATION NECESSARY TO KNOW WHETHER ITS SALES OF MUNICIPAL SECURITIES WOULD OR DID MEET THE LIMITED OFFERING EXEMPTION REQUIREMENTS. THE 354 VIOLATIVE OFFERINGS THAT OPPENHEIMER CONDUCTED DID NOT MEET THE LIMITED OFFERING EXEMPTION REQUIREMENTS, AND OPPENHEIMER KNEW OR SHOULD HAVE KNOWN ITS STATEMENTS TO THE CONTRARY WERE DECEPTIVE. IN CONNECTION WITH THE 354 VIOLATIVE OFFERINGS IT CONDUCTED, OPPENHEIMER REALIZED AT LEAST $1,938,580 IN NET PROFITS. UPON INFORMATION AND BELIEF, OPPENHEIMER CONTINUES TO UNDERWRITE WHAT IT PURPORTS TO BE LIMITED OFFERINGS OF NEW ISSUE MUNICIPAL SECURITIES WITHOUT SATISFYING THE LIMITED OFFERING EXEMPTION REQUIREMENTS. UPON INFORMATION AND BELIEF, OPPENHEIMER HAS ALSO FAILED TO IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE LIMITED OFFERING EXEMPTION. ACCORDINGLY, OPPENHEIMER VIOLATED EXCHANGE ACT RULE 15C2-12, MSRB RULE G-27, MSRB RULE G-17, AND EXCHANGE ACT SECTION 15B(C)(1).
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, HURTADO CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE RECOMMENDED AND EFFECTED UNSUITABLE PUT SPREAD INVESTMENT STRATEGIES IN THE ACCOUNTS OF TWO CUSTOMERS. THE FINDINGS STATED THAT THIS MATTER AROSE FROM THE FILING OF A UNIFORM APPLICATION FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER FORM (FORM U4) THAT DISCLOSED CUSTOMER COMPLAINTS REGARDING HURTADO'S CONDUCT. THE FINDINGS ALSO STATED THAT HURTADO UNDERSTOOD THAT PUT SPREADS ARE DESIGNED AS A RISK-CONTAINMENT STRATEGY AND RECOMMENDED SUCH INVESTMENTS, HOWEVER, WITH CERTAIN PUT SPREAD TRANSACTIONS, HE RECOMMENDED THAT THE CUSTOMERS FOREGO THIS RISK MITIGATION MECHANISM. THE FINDINGS ALSO STATED THAT IN MANY INSTANCES, AFTER THE CUSTOMER HELD THE SECURITY FOR A PERIOD OF TIME, HURTADO RECOMMENDED THAT THE CUSTOMER SELL THE SECURITY AT A LOSS LARGER THAN THE ORIGINAL PUT SPREAD'S MAXIMUM LOSS. THE FINDINGS ALSO STATED THAT HURTADO ALSO MAGNIFIED THE RISK OF NUMEROUS PUT SPREAD TRANSACTIONS, AND SUBSEQUENT ASSIGNMENTS, BY RECOMMENDING THAT THE TWO CUSTOMERS FUND ASSIGNMENTS ON MARGIN, THUS INCREASING RISK BY EXPOSING THE ACCOUNT TO MARGIN CALLS AND BY REQUIRING THE CUSTOMER TO PAY INTEREST ON THE MARGIN LOAN. THE FINDINGS ALSO STATED THAT BOTH ACCOUNTS SAW INDIVIDUAL ASSIGNMENTS OF NEARLY $1 MILLION FUNDED ON MARGIN. THE FINDINGS ALSO STATED THAT HURTADO ALSO RECOMMENDED THAT THE CUSTOMERS OVER-CONCENTRATE THEIR OPTIONS INVESTMENTS IN THE ENERGY SECTOR, FURTHER INCREASING THE RISK OF LOSS ONCE THE CUSTOMERS TOOK ASSIGNMENT OF THE SUBJECT SECURITIES. THE FINDINGS ALSO STATED THAT HURTADO'S RECOMMENDATIONS CAUSED APPROXIMATELY $1.6 MILLION IN NET LOSSES FOR THE TWO CUSTOMERS. THE FINDINGS ALSO STATED THAT BOTH CUSTOMERS SETTLED CLAIMS AGAINST HURTADO'S MEMBER FIRM IN CONNECTION WITH HIS CONDUCT FOR A TOTAL AMOUNT OF $560,000, TO WHICH HURTADO PERSONALLY CONTRIBUTED $280,000. Status: Final Sanction Detail: SUSPENDED IN ALL CAPACITIES FOR 45 DAYS, BEGINNING SEPT 7, 2021 AND ENDING OCTOBER 21, 2021. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, HURTADO CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE RECOMMENDED AND EFFECTED UNSUITABLE PUT SPREAD INVESTMENT STRATEGIES IN THE ACCOUNTS OF TWO CUSTOMERS. THE FINDINGS STATED THAT THIS MATTER AROSE FROM THE FILING OF A UNIFORM APPLICATION FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER FORM (FORM U4) THAT DISCLOSED CUSTOMER COMPLAINTS REGARDING HURTADO'S CONDUCT. THE FINDINGS ALSO STATED THAT HURTADO UNDERSTOOD THAT PUT SPREADS ARE DESIGNED AS A RISK-CONTAINMENT STRATEGY AND RECOMMENDED SUCH INVESTMENTS, HOWEVER, WITH CERTAIN PUT SPREAD TRANSACTIONS, HE RECOMMENDED THAT THE CUSTOMERS FOREGO THIS RISK MITIGATION MECHANISM. THE FINDINGS ALSO STATED THAT IN MANY INSTANCES, AFTER THE CUSTOMER HELD THE SECURITY FOR A PERIOD OF TIME, HURTADO RECOMMENDED THAT THE CUSTOMER SELL THE SECURITY AT A LOSS LARGER THAN THE ORIGINAL PUT SPREAD'S MAXIMUM LOSS. THE FINDINGS ALSO STATED THAT HURTADO ALSO MAGNIFIED THE RISK OF NUMEROUS PUT SPREAD TRANSACTIONS, AND SUBSEQUENT ASSIGNMENTS, BY RECOMMENDING THAT THE TWO CUSTOMERS FUND ASSIGNMENTS ON MARGIN, THUS INCREASING RISK BY EXPOSING THE ACCOUNT TO MARGIN CALLS AND BY REQUIRING THE CUSTOMER TO PAY INTEREST ON THE MARGIN LOAN. THE FINDINGS ALSO STATED THAT BOTH ACCOUNTS SAW INDIVIDUAL ASSIGNMENTS OF NEARLY $1 MILLION FUNDED ON MARGIN. THE FINDINGS ALSO STATED THAT HURTADO ALSO RECOMMENDED THAT THE CUSTOMERS OVER-CONCENTRATE THEIR OPTIONS INVESTMENTS IN THE ENERGY SECTOR, FURTHER INCREASING THE RISK OF LOSS ONCE THE CUSTOMERS TOOK ASSIGNMENT OF THE SUBJECT SECURITIES. THE FINDINGS ALSO STATED THAT HURTADO'S RECOMMENDATIONS CAUSED APPROXIMATELY $1.6 MILLION IN NET LOSSES FOR THE TWO CUSTOMERS. THE FINDINGS ALSO STATED THAT BOTH CUSTOMERS SETTLED CLAIMS AGAINST HURTADO'S MEMBER FIRM IN CONNECTION WITH HIS CONDUCT FOR A TOTAL AMOUNT OF $560,000, TO WHICH HURTADO PERSONALLY CONTRIBUTED $280,000.
Allegations: SEC ADMIN RELEASE 34-73509, NOVEMBER 3, 2014: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST OPPENHEIMER & CO., INC. ("OPPENHEIMER" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT: THESE PROCEEDINGS INVOLVE THE SALE OF NON-INVESTMENT GRADE OR "JUNK" BONDS ISSUED BY THE COMMONWEALTH OF PUERTO RICO ("PUERTO RICO") BY OPPENHEIMER, A REGISTERED BROKER-DEALER AND MUNICIPAL SECURITIES DEALER, TO CUSTOMERS IN AMOUNTS BELOW THE MINIMUM DENOMINATION OF THE ISSUE. RULE G-15(F) PROMULGATED BY THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") PROHIBITS DEALERS FROM EFFECTING CUSTOMER TRANSACTIONS IN MUNICIPAL SECURITIES IN AMOUNTS BELOW THE MINIMUM DENOMINATIONS OF THE ISSUES. MINIMUM DENOMINATIONS ARE GENERALLY INTENDED TO LIMIT SALES OF MUNICIPAL SECURITIES TO RETAIL CUSTOMERS FOR WHOM SUCH BONDS MAY NOT BE SUITABLE, BUT THE PROSCRIPTIONS OF RULE G-15(F) APPLY TO ALL TRANSACTIONS WITH CUSTOMERS, REGARDLESS OF WHETHER THE SECURITIES ARE SUITABLE FOR THE CUSTOMER. IN MARCH 2014, OPPENHEIMER VIOLATED MSRB RULE G-15(F) BY EXECUTING THREE UNSOLICITED SALES TRANSACTIONS IN THE PUERTO RICO BONDS WITH CUSTOMERS IN AMOUNTS BELOW THE $100,000 MINIMUM DENOMINATION OF THE ISSUE ESTABLISHED BY THE ISSUER, PUERTO RICO, AND SPECIFIED IN THE OFFICIAL STATEMENT. THE LIMITED EXCEPTIONS PROVIDED UNDER MSRB RULE G-15(F) FOR CUSTOMER TRANSACTIONS IN MUNICIPAL SECURITIES BELOW THE MINIMUM DENOMINATION OF AN ISSUE DID NOT APPLY TO THESE TRANSACTIONS. RESPONDENT DID NOT HAVE ANY POLICIES OR PROCEDURES CONCERNING MSRB RULE G-15(F). AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED MSRB RULE G-15(F). AS A RESULT OF RESPONDENT'S WILLFUL VIOLATIONS OF MSRB RULE G-15(F), RESPONDENT WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. Status: Final Sanction Detail: ACCORDINGLY, IT IS HEREBY ORDERED THAT: RESPONDENT CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT AND MSRB RULE G-15(F) . RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN SEVEN (7) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $61,200. RESPONDENT WILLFULLY VIOLATED MSRB RULE G-15(F). AS A RESULT OF RESPONDENT'S WILLFUL VIOLATIONS OF MSRB RULE G-15(F), RESPONDENT WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. Summary: IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY RESPONDENT. AFTER IT WAS MADE AWARE THAT IT HAD EFFECTED CUSTOMER TRANSACTIONS IN THE 2014 BONDS BELOW THE MINIMUM DENOMINATION OF THE ISSUE, RESPONDENT CANCELLED THE TRANSACTIONS. RESPONDENT WILL UNDERTAKE TO REVIEW THE ADEQUACY OF ITS EXISTING POLICIES AND PROCEDURES RELATING TO COMPLIANCE WITH MSRB RULE G-15(F). AFTER THAT REVIEW, RESPONDENT WILL MAKE SUCH CHANGES AS ARE NECESSARY TO EFFECT COMPLIANCE WITH MSRB RULE G-15(F), INCLUDING ADOPTING NEW POLICIES AND PROCEDURES OR SUPPLEMENTING EXISTING POLICIES AND PROCEDURES. RESPONDENT WILL IMPLEMENT THESE POLICIES AND PROCEDURES, AND CONDUCT TRAINING AS TO THE POLICIES AND PROCEDURES AND COMPLIANCE WITH MSRB RULE G-15(F). RESPONDENT WILL INFORM COMMISSION STAFF NO LATER THAN SIX (6) MONTHS AFTER THE ENTRY OF THIS ORDER THAT IT HAS COMPLIED WITH THE ABOVE UNDERTAKINGS.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), THAT WERE REASONABLY DESIGNED TO SUPERVISE THE SUITABILITY OF REPRESENTATIVES' RECOMMENDATIONS TO CUSTOMERS AS THEY PERTAIN TO EARLY ROLLOVERS OF UNIT INVESTMENT TRUSTS (UITS). Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $800,000, AND ORDERED TO PAY RESTITUTION TO THE CUSTOMERS IN THE TOTAL AMOUNT OF $3,874,206.90 Summary: IN RESOLVING THIS MATTER, FINRA HAS RECOGNIZED THE FIRM'S EXTRAORDINARY COOPERATION.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO RECORD NOT HELD TERMS AND CONDITIONS ON ITS ORDER MEMORANDA FOR INSTITUTIONAL CUSTOMERS OF ONE OF THE FIRM'S TRADING DESKS AND FOR THE SAME ORDERS, IT TRANSMITTED REPORTS TO OATS THAT FAILED TO CONTAIN THAT NOT HELD SPECIAL HANDLING CODE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND ESTABLISH, MAINTAIN, AND ENFORCE WSPS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES OF FINRA CONCERNING MAINTAINING ACCURATE BOOKS AND RECORDS, SPECIFICALLY ORDER MEMORANDA. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $85,000 AND REQUIRED TO REVISE ITS WSPS. Summary: THE FIRM WAS CENSURED, FINED $85,000 AND REQUIRED TO REVISE ITS WSPS.
Allegations: OPPENHEIMER & CO. INC VIOLATED CBOE RULES 4.24 AND 8.16 IN THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE LOPR RULES. Status: Final Sanction Detail: A CENSURE, A MONETARY FINE IN THE AMOUNT OF $450,000 AND AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT. Summary: OPPENHEIMER & CO. INC VIOLATED CBOE RULES 4.24 AND 8.16 IN THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE LOPR RULES. A CENSURE, A MONETARY FINE IN THE AMOUNT OF $450,000 AND AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT.
Allegations: IN JULY, 2015 , THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE ISSUED A STATEMENT OF CHARGES, IN THE MATTER OF OPPENHEIMER & CO. INC. STAR NO. 20150462954, ALLEGING THAT OPPENHEIMER VIOLATE EXCHANGE RULE 3.6A BY FAILING TO TWO ASSOCIATED PERSONS AS PROPRIETARY TRADER PRINCIPALS,5 ASSOCIATED PERSONS AS PROPRIETARY TRADERS, AND THE CHIEF COMPLIANCE OFFICER AS PROPRIETARY TRADER COMPLIANCE OFFICER. Status: Final Sanction Detail: ON OCTOBER 20, 2015 THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED UNDER FILE NO. 15-0070, STAR NO. 20150462954 ISSUED ITS DECISION ACCEPTING THE OFFER OF SETTLEMENT IN THE MATTER OF OPPENHEIMER & CO. INC. ("THE DECISION"). THE DECISION DETERMINED THAT OPPENHEIMER WAS AN EXCHANGE TRADING PERMIT HOLDER APPROVED TO TRANSACT BUSINESS WITH THE PUBLIC. AS A RESULT OF A ROUTINE EXAMINATION IT WAS DETERMINED THAT ON VARIOUS DATES FROM NOVEMBER 5, 2011 THROUGH JUNE 9, 2014, OPPENHEIMER FAILED TO REGISTER TWO (2) ASSOCIATED PERSONS AS PROPRIETARY TRADING PRINCIPAL WITH CBOE. DURING THE SAME PERIOD OF TIME OPPENHEIMER FAILED TO REGISTER FICE (5) ASSOCIATED PERSONS AS PROPRIETARY TRADERS, AND FROM MAY 1, 2013 THROUGH SEPTEMBER 17, 2013 OPPENHEIMER FAILED TO REGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADING COMPLIANCE OFFICER. OPPENHEIMER WAS SANCTIONED, AND ORDERED TO PAY $20,000.00 TO THE CBOE.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FROM JANUARY 2009 THROUGH SEPTEMBER 2014, THE FIRM FAILED TO REASONABLY SUPERVISE AND TO HAVE AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING ADEQUATE WRITTEN SUPERVISORY PROCEDURES (WSPS), TO ADDRESS SHORT POSITIONS IN TAX-EXEMPT MUNICIPAL BONDS THAT RESULTED PRIMARILY FROM TRADING ERRORS. THE FINDINGS STATED THAT AS A RESULT OF THESE SUPERVISORY FAILURES, THE FIRM INACCURATELY REPRESENTED TO ITS CUSTOMERS HOLDING MUNICIPAL BONDS THAT AT LEAST $188,974.38 IN INTEREST THAT THE FIRM PAID TO THOSE CUSTOMERS WAS EXEMPT FROM TAXATION. THE FIRM DID NOT HOLD THE BONDS ON BEHALF OF THE CUSTOMERS AND THE INTEREST THAT THE CUSTOMERS RECEIVED WAS PAID BY THE FIRM AND THUS TAXABLE AS ORDINARY INCOME. THE FIRM FAILED TO CONSIDER, AND ITS DIVIDEND DEPARTMENT THAT WAS RESPONSIBLE FOR DISTRIBUTING AND RECONCILING THE INTEREST OWED TO CUSTOMERS DID NOT TAKE INTO ACCOUNT, WHETHER THE INTEREST PAID TO CUSTOMERS SHOULD BE CODED AS NON-TAXABLE WHEN THE INTEREST WAS PAID BY THE FIRM RATHER THAN THE MUNICIPAL ISSUER. THE FINDINGS ALSO STATED THAT THE FIRM DID NOT PROVIDE ADEQUATE GUIDANCE OR OVERSIGHT ON HOW AND WHEN MUNICIPAL SHORT POSITIONS SHOULD BE COVERED. AS A RESULT OF THE FIRM'S PROCEDURES, OR LACK THEREOF, REGARDING MUNICIPAL SHORT POSITIONS IN BRANCH ERROR ACCOUNTS AND FIRM TRADING ACCOUNTS, MANY OF THE SHORT POSITIONS WERE NOT COVERED IN A TIMELY FASHION. THIS DEFICIENCY MAY HAVE BEEN PROLONGED DUE TO THE DIFFICULTY OF COVERING THESE POSITIONS IN LIGHT OF THE CHARACTERISTICS OF MUNICIPAL SECURITIES AS WELL AS THE LIMITED AMOUNT OUTSTANDING OF A PARTICULAR MUNICIPAL BOND. IN 2013, THE FIRM RECOGNIZED THAT SHORT POSITIONS WERE NOT BEING COVERED IN A TIMELY FASHION AND SUBSEQUENTLY REVISED ITS PROCEDURES TO REDUCE THE NUMBER OF AGED SHORT POSITIONS. NEVERTHELESS, DURING THE RELEVANT PERIOD, THE FIRM OFTEN DID NOT COVER MUNICIPAL SHORT POSITIONS. THE FIRM HAS ALSO IMPLEMENTED REVISED PROCEDURES TO MINIMIZE ITS SHORT MUNICIPAL BOND POSITIONS AND TO PROPERLY REPORT FIRM-PAID INTEREST AS TAXABLE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO DISCLOSE TO CUSTOMERS THAT THEY WERE NOT RECEIVING TAX-EXEMPT INTEREST WHEN THE FIRM WAS SHORT MUNICIPAL BONDS. IN ADDITION, THE FIRM SENT INACCURATE FORMS 1099 TO CERTAIN CUSTOMERS WHO RECEIVED FIRM-PAID INTEREST FOR 2009 THROUGH 2014 AND ALSO SENT INACCURATE ACCOUNT STATEMENTS TO CERTAIN CUSTOMERS THAT INCORRECTLY CLASSIFIED FIRM-PAID INTEREST AS TAX-EXEMPT WHEN IT SHOULD HAVE BEEN CLASSIFIED AS TAXABLE. IN 2013, FINRA EXAMINATION STAFF FOUND THAT THE FIRM HAD INACCURATELY REPORTED FIRM-PAID INTEREST FROM SHORT MUNICIPAL BOND POSITIONS TO CUSTOMERS ON FORMS 1099 AND ACCOUNT STATEMENTS. THEREAFTER, THE FIRM IMPLEMENTED REVISED PROCEDURES TO MINIMIZE ITS SHORT MUNICIPAL POSITIONS AND PROPERLY REPORT FIRM-PAID INTEREST AS TAXABLE ON THE FORMS 1099 ISSUED TO CUSTOMERS. THE FIRM HAS ALSO AGREED IN PRINCIPAL WITH THE IRS TO MAKE A PAYMENT TO RELIEVE ITS CUSTOMERS OF THE BURDEN OF FILING AMENDED TAX RETURNS AND PAYING ADDITIONAL FEDERAL INCOME TAX. FINRA FOUND THAT DURING THE RELEVANT PERIOD, THE FIRM DID NOT MAINTAIN RECORDS IDENTIFYING PARTICULAR CUSTOMER ACCOUNTS THAT OFFSET ITS SHORT MUNICIPAL BOND POSITIONS. THE FIRM'S SHORT POSITIONS WERE HELD IN AGGREGATE AND NOT ALLOCATED TO SPECIFIED CUSTOMERS. BECAUSE THE FIRM'S SHORT MUNICIPAL BOND POSITIONS WERE NOT OFFSET AGAINST SPECIFIC CUSTOMER HOLDINGS, THE FIRM WAS UNABLE TO ACCURATELY REPORT TAXABLE INCOME TO ITS CUSTOMERS WHO WERE RECEIVING FIRM-PAID INTEREST AS TAXABLE INCOME. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $225,000.00
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, PEJOUHESH CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPROPERLY DIRECTED AND ALLOWED HIS INTERN AT HIS MEMBER FIRM TO COMPLETE 14 HOURS OF CONTINUING EDUCATION (CE) COURSES RELATED TO PEJOUHESH'S CERTIFIED FINANCIAL PLANNER (CFP) DESIGNATION ON HIS BEHALF, RATHER THAN COMPLETING THEM HIMSELF AFTER HIS CFP CERTIFICATION WAS DEEMED RELINQUISHED DUE TO, AMONG OTHER THINGS, HIS FAILURE TO COMPLETE REQUIRED CE. Status: Final Sanction Detail: SUSPENDED FROM 8/7/2023 THROUGH 9/6/2023 IN ALL REGISTERED CAPACITIES. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, PEJOUHESH CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPROPERLY DIRECTED AND ALLOWED HIS INTERN AT HIS MEMBER FIRM TO COMPLETE 14 HOURS OF CONTINUING EDUCATION (CE) COURSES RELATED TO PEJOUHESH'S CERTIFIED FINANCIAL PLANNER (CFP) DESIGNATION ON HIS BEHALF, RATHER THAN COMPLETING THEM HIMSELF AFTER HIS CFP CERTIFICATION WAS DEEMED RELINQUISHED DUE TO, AMONG OTHER THINGS, HIS FAILURE TO COMPLETE REQUIRED CE.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, VATTEROTT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY FALSIFYING THE REPRESENTATIVE CODE FOR TRADES IN HIS FIRM'S ORDER ENTRY SYSTEM, CAUSING THE TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT VATTEROTT ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A FORMER REPRESENTATIVE. THE AGREEMENT SET FORTH WHAT PERCENTAGES OF THE COMMISSIONS VATTEROTT AND THE FORMER REPRESENTATIVE'S ESTATE EARNED ON TRADES PLACED USING THE JOINT REPRESENTATIVE CODE. VATTEROTT PLACED TRADES IN ACCOUNTS THAT WERE COVERED BY THE AGREEMENT USING A REPRESENTATIVE CODE OTHER THAN THE ONE HE SHOULD HAVE USED. SPECIFICALLY, ALTHOUGH HIS FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE JOINT REPRESENTATIVE CODE VATTEROTT SHARED WITH THE REPRESENTATIVE'S ESTATE PURSUANT TO THE JOINT PRODUCTION AGREEMENT, VATTEROTT ENTERED THE TRANSACTIONS UNDER A DIFFERENT REPRESENTATIVE CODE. VATTEROTT CHANGED THE CODES BECAUSE HE MISTAKENLY BELIEVED THAT THE JOINT PRODUCTION AGREEMENT DID NOT APPLY TO NEW ASSETS ADDED TO ACCOUNTS SUBJECT TO THE AGREEMENT AND THAT HE WAS AUTHORIZED TO ENTER THE TRADES USING THE OTHER REPRESENTATIVE CODE. HOWEVER, VATTEROTT DID NOT DO ANYTHING TO CONFIRM HIS UNDERSTANDING, SUCH AS ASKING THE ESTATE WHETHER HE COULD CHANGE THE REPRESENTATIVE CODES ON THE TRADES AT ISSUE OR SPEAKING WITH HIS FIRM TO VERIFY WHETHER THE TRANSACTIONS AT ISSUE WERE SUBJECT TO THE JOINT PRODUCTION AGREEMENT. AFTER VATTEROTT'S FIRM PAID RESTITUTION TO THE REPRESENTATIVE'S ESTATE, VATTEROTT REIMBURSED THE FIRM APPROXIMATELY $87,500, WHICH IS THE APPROXIMATE AMOUNT OF THE ADDITIONAL COMMISSION THAT HE RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON THE TRADES. Status: Final Sanction Detail: SUSPENSION FOR 6 MONTHS IN ALL REGISTRATION CAPACITIES. START DATE: 01/02/2024. END DATE: 07/01/2024. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, VATTEROTT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY FALSIFYING THE REPRESENTATIVE CODE FOR TRADES IN HIS FIRM'S ORDER ENTRY SYSTEM, CAUSING THE TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT VATTEROTT ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A FORMER REPRESENTATIVE. THE AGREEMENT SET FORTH WHAT PERCENTAGES OF THE COMMISSIONS VATTEROTT AND THE FORMER REPRESENTATIVE'S ESTATE EARNED ON TRADES PLACED USING THE JOINT REPRESENTATIVE CODE. VATTEROTT PLACED TRADES IN ACCOUNTS THAT WERE COVERED BY THE AGREEMENT USING A REPRESENTATIVE CODE OTHER THAN THE ONE HE SHOULD HAVE USED. SPECIFICALLY, ALTHOUGH HIS FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE JOINT REPRESENTATIVE CODE VATTEROTT SHARED WITH THE REPRESENTATIVE'S ESTATE PURSUANT TO THE JOINT PRODUCTION AGREEMENT, VATTEROTT ENTERED THE TRANSACTIONS UNDER A DIFFERENT REPRESENTATIVE CODE. VATTEROTT CHANGED THE CODES BECAUSE HE MISTAKENLY BELIEVED THAT THE JOINT PRODUCTION AGREEMENT DID NOT APPLY TO NEW ASSETS ADDED TO ACCOUNTS SUBJECT TO THE AGREEMENT AND THAT HE WAS AUTHORIZED TO ENTER THE TRADES USING THE OTHER REPRESENTATIVE CODE. HOWEVER, VATTEROTT DID NOT DO ANYTHING TO CONFIRM HIS UNDERSTANDING, SUCH AS ASKING THE ESTATE WHETHER HE COULD CHANGE THE REPRESENTATIVE CODES ON THE TRADES AT ISSUE OR SPEAKING WITH HIS FIRM TO VERIFY WHETHER THE TRANSACTIONS AT ISSUE WERE SUBJECT TO THE JOINT PRODUCTION AGREEMENT. AFTER VATTEROTT'S FIRM PAID RESTITUTION TO THE REPRESENTATIVE'S ESTATE, VATTEROTT REIMBURSED THE FIRM APPROXIMATELY $87,500, WHICH IS THE APPROXIMATE AMOUNT OF THE ADDITIONAL COMMISSION THAT HE RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON THE TRADES. MATTER RESOLVED 12/04/2023 BY AWC. CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) OF $5,000. SUSPENSION FOR 6 MONTHS IN ALL REGISTRATION CAPACITIES. SUSPENSION START DATE: 01/02/2024. END DATE: 07/01/2024.
Allegations: GIVEN THE FACTS AND CIRCUMSTANCES SURROUNDING MICHIENZI'S APRIL 2021 TERMINATION FROM MORGAN STANLEY, THE MASSACHUSETTS SECURITIES DIVISION ALLOWED MICHIENZI'S REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE IN MASSACHUSETTS AND ALLOWED HIS CONTINUED REGISTRATION AS A BROKER-DEALER AGENT IN MASSACHUSETTS PURSUANT TO A TWO (2) YEAR PLAN OF HEIGHTENED SUPERVISION. Status: Final Sanction Detail: NOT APPLICABLE Summary: GIVEN THE FACTS AND CIRCUMSTANCES SURROUNDING MICHIENZI'S APRIL 2021 TERMINATION FROM MORGAN STANLEY, THE MASSACHUSETTS SECURITIES DIVISION ALLOWED MICHIENZI'S REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE IN MASSACHUSETTS AND ALLOWED HIS CONTINUED REGISTRATION AS A BROKER-DEALER AGENT IN MASSACHUSETTS PURSUANT TO A TWO (2) YEAR PLAN OF HEIGHTENED SUPERVISION.
Allegations: IN NOVEMBER, 2014 THE NEW MEXICO SECURITIES DIVISION FILED A NOTICE OF CONTEMPLATED ACTION, IN THE MATTER OF OPPENHEIMER AND ROYCE SIMPSON, NN. 14-03-0028 ('THE NOTICE"). THE NOTICE ALLEGED THAT CERTAIN FEDERAL NATIONAL MORTGAGE ASSOCIATION AND FEDERAL LOAN HOME BANK BONDS, PURCHASED BY BERNALILLO COUNTY WERE UNSUITABLE, AND THAT CO- RESPONDENT SIMPSON'S ACTIVITIES WEREN'T SUPERVISED. THE MATTER HAS NOT BEEN SCHEDULED FOR A HEARING. Status: Final Sanction Detail: ON OCTOBER 19, 2015 OPPENHEIMER & CO. INC. ("OPPENHEIMER") ENTERED A STIPULATION AND AGREEMENT WITH THE DIRECTOR OF THE SECURITIES DIVISION OF THE NEW MEXICO REGULATION AND LICENSING DEPARTMENT RESOLVING A NOTICE OF CONTEMPLATED ACTION, DATED NOVEMBER 20, 2014, CAPTIONED IN THE MATTER OF OPPENHEIMER & CO. INC. AND ROYCE SIMPSON, CASE NO. 14-03-0028. THE STIPULATION AND AGREEMENT DETERMINED THAT THE DIVISION, WHILE REVIEWING THE TRADING ACTIVITY FOR BERNALILLO COUNTY FROM 2012 THROUGH 2013, DETERMINED THAT THERE MAY HAVE BEEN CERTAIN SUPERVISORY DEFICIENCIES AT OPPENHEIMER IN ADVISING THE TREASURER'S OFFICE OF BERNALILLO COUNTY DURING THE PERIOD OF TIME IN QUESTION THROUGH OPPENHEIMER'S AGENT, ROYCE SIMPSON. OPPENHEIMER DISPUTES THAT CLAIM AS SET FORTH IN THE NOTICE OF CONTEMPLATED ACTION; FURTHER, THE STIPULATION AND AGREEMENT WAS NOT INTENDED TO MODIFY ANY OF OPPENHEIMER'S OBLIGATIONS UNDER EXISTING LAW, AND IN FACT OPPENHEIMER MADE CERTAIN REVISIONS IN ITS INTERNAL POLICIES INVOLVING THE INVESTMENT OF PUBLIC FUNDS. OPPENHEIMER ALSO AGREED TO REMIT TO THE DIVISION THE AMOUNT OF $215,000.00, TO BE ALLOCATED TO THE INVESTOR EDUCATION FUND FOR THE BENEFIT OF LICENSEES AND CONSUMERS WITHIN OF NEW MEXICO. OPPENHEIMER MADE THAT PAYMENT ON NOVEMBER 7, 2015. OPPENHEIMER ALSO AGREED TO COMMIT TO A FULL IMPLEMENTATION OF IMPROVED SUPERVISORY PROCEDURES, WHICH IT ALREADY ADOPTED, FOR SERVICING POLITICAL SUBDIVISIONS THROUGHOUT NEW MEXICO. AS A RESULT, THE DIVISION RELEASED AND DISCHARGED OPPENHEIMER FROM MANY AND ALL CLAIMS, AND DISMISSED THE NOTICE OF CONTEMPLATED ACTION WITH PREJUDICE AGAINST OPPENHEIMER.
Allegations: THE INVESTIGATION DETERMINED THAT BETWEEN JANUARY 2003 AND NOVEMBER 2015, RESPONDENT FAILED TO COMPLY WITH NAC 90.330, WHICH REQUIRES THE LICENSUE OF ALL INVESTMENT ADVISOR REPRESENTATIVES ENGAGED IN SECURITIES-RELATED BUSINESS IN OR FROM THE STATE OF NEVADA. Status: Final Sanction Detail: CIVIL FINE - $8000.00 AND INVESTIGATIVE FINE - $569.58 Summary: THE INVESTIGATION DETERMINED THAT BETWEEN JANUARY 2003 AND NOVEMBER 2015, RESPONDENT FAILED TO COMPLY WITH NAC 90.330, WHICH REQUIRES THE LICENSUE OF ALL INVESTMENT ADVISOR REPRESENTATIVES ENGAGED IN SECURITIES-RELATED BUSINESS IN OR FROM THE STATE OF NEVADA.
Allegations: THE LICENSEE UNKNOWINGLY ENGAGED IN THE BUSINESS OF INSURANCE DURING THE PERIOD THE LICENSEE'S PRODUCER LICENSE LAPSED BY SELLING INSURANCE AND RECEIVING COMMISSIONS (4/30/23-6/6/23). THE LICENSEE SHALL PAY A FINE TO THE DEPARTMENT IN THE AMOUNT OF $250.00 Status: Final Sanction Detail: CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S). MONETARY/FINE AMOUNT OF $250.00 Summary: THE LICENSEE UNKNOWINGLY ENGAGED IN THE BUSINESS OF INSURANCE DURING THE PERIOD THE LICENSEE'S PRODUCER LICENSE LAPSED BY SELLING INSURANCE AND RECEIVING COMMISSIONS (4/30/23-6/6/23). THE LICENSEE SHALL PAY A FINE TO THE DEPARTMENT IN THE AMOUNT OF $250.00
Allegations: ON 3/23/2023, FLORIDA DEPARTMENT OF FINANCIAL SERVICES ENTERED AN ORDER OF SUSPENSION FOR A PERIOD OF FORTY-FIVE DAYS. DURING THE SUSPENSION OF THE LICENSE OR APPOINTMENTS AND UNTIL THE LICENSE IS REINSATED, THE RESPONDENT SHALL NOT ENGAGE IN OR ATTEMPT OR PROFESS TO ENGAGE IN ANY TRANSACTION OR BUSINESS FOR WHICH A LICENSE OR APPOINTMENT IS REQUIRED. Status: Final Sanction Detail: SUSPENSION OF 45 DAYS. START DATE: 3/23/2023; END DATE: 5/6/2023 Summary: ON 3/23/2023, FLORIDA DEPARTMENT OF FINANCIAL SERVICES ENTERED AN ORDER OF SUSPENSION FOR A PERIOD OF FORTY-FIVE DAYS. DURING THE SUSPENSION OF THE LICENSE OR APPOINTMENTS AND UNTIL THE LICENSE IS REINSATED, THE RESPONDENT SHALL NOT ENGAGE IN OR ATTEMPT OR PROFESS TO ENGAGE INANY TRANSACTION OR BUSINESS FOR WHICH A LICENSE OR APPOINTMENT IS REQUIRED.
Allegations: BETWEEN JANUARY 2014 AND FEBRUARY 2018 MR. VANECH REQUESTED HIS CLIENT SERVICE ASSOCIATE TO COMPLETE CONTINUING EDUCATION MODULES ON HIS BEHALF, AND DID NOT COMPLETE THIS TRAINING HIMSELF, IN VIOLATION OF FINRA RULE 2010. Status: Final Sanction Detail: MR. VANECH IS SUSPENDED FROM ASSOCIATION WITH ANY FINRA FIRM IN ANY CAPACITY FOR THREE MONTHS. THE SANCTIONS IMPOSED SHALL BE EFFECTIVE ON A DATE SET BY FINRA STAFF. Summary: BETWEEN JANUARY 2014 AND FEBRUARY 2018 MR. VANECH REQUESTED HIS CLIENT SERVICE ASSOCIATE TO COMPLETE CONTINUING EDUCATION MODULES ON HIS BEHALF, AND DID NOT COMPLETE THIS TRAINING HIMSELF, IN VIOLATION OF FINRA RULE 2010. MR. VANECH WAS SUSPENDED FROM ASSOCIATION WITH ANY FINRA FIRM IN ANY CAPACITY FOR THREE MONTHS, FINED $3,000 AND MUST COMPLETE TEN HOURS OF CONTINUING EDUCATION THROUGH A PROVIDER NOT UNACCEPTABLE TO FINRA.
Allegations: VANECH WAS PREVIOUSLY THE SUBJECT OF A FINRA REGULATORY ACTION AS A RESULT OF ALLOWING HIS CLIENT SERVICE ASSOCIATE AT HIS MEMBER FIRM COMPLETE HIS FIRM ELEMENT CONTINUING EDUCATION MODULES ON HIS BEHALF. AT THE TIME OF THE PREVIOUS ACTION, OPPENHEIMER REMOVED VANECH'S MASSACHUSETTS REGISTRATION. NOW, IN ORDER TO RE-REGISTER VANECH, MASSACHUSETTS HAS REQUIRED A CONSENT ORDER. Status: Final Sanction Detail: FOR A PERIOD OF TWO (2) YEARS FROM THE DATE OF THE ENTRY OF THIS ORDER, HEIGHTENED SUPERVISION OF VANECH MUST, AT A MINIMUM, INCLUDE THE FOLLOWING: A. FOR ALL OF VANECH'S CONTINUING EDUCATION TRAINING, VANECH MUST NOTIFY HIS SUPERVISOR, AS TO THE TITLE(S) OF THE CONTINUING EDUCATION TRAINING COMPLETED, THE DATE COMPLETED, AND SUBMIT A SIGNED STATEMENT ATTESTING TO THE FACT THAT VANECH PERSONALLY COMPLETED THE TRAINING (THE "TRAINING ATTESTATION"). THE TRAINING ATTESTATION MUST BE MEMORIALIZED IN WRITING AND A COPY MUST BE PLACED INTO VANECH'S PERSONNEL FILE; B. ON AN ANNUAL BASIS, THE COMPLIANCE DEPARTMENT MUST REVIEW THE TRAINING ATTESTATION(S) SUBMITTED BY VANECH AND INTERNALLY VERIFY VANECH'S CONTINUING EDUCATION TRAINING WAS COMPLETED PERSONALLY BY VANECH. ALL REVIEWS MUST BE UNDERTAKEN TO DETECT AND PREVENT POTENTIAL SECURITIES LAW AND OPPENHEIMER POLICY AND PROCEDURE VIOLATIONS AND BE MEMORIALIZED IN WRITING INCLUDING BUT NOT LIMITED TO, THE STEPS THE COMPLIANCE DEPARTMENT TOOK TO VERIFY THE TRAINING WAS COMPLETED PERSONALLY BY VANECH, THE RESULTS OF THE REVIEW AND ANY ACTIONS TAKEN. A COPY OF THE REVIEW MUST BE MEMORIALIZED INWRITING BY THE COMPLIANCE DEPARTMENT; AND C. THE COMPLIANCE DEPARTMENT'S ANNUAL AUDIT OF THE BRANCH OFFICE MUST OCCUR AT THE BRANCH OFFICE, TO THE EXTENT POSSIBLE DUE TO DIFFICULTIES ARISING FROM THE COVID-19PANDEMIC, AND MUST INCLUDE A MANDATORY REVIEW OF VANECH'S CONTINUING EDUCATION REQUIREMENTS AND TRAINING ATTESTATION(S) IN VANECH'S PERSONNEL FILE. ALL REVIEWS MUST BE UNDERTAKEN TO DETECT AND PREVENT POTENTIAL SECURITIES LAW AND OPPENHEIMER POLICY AND PROCEDURE VIOLATIONS AND BE MEMORIALIZED IN WRITING INCLUDING BUT NOT LIMITED TO, TITLE(S) OF TRAINING COMPLETED, DATE COMPLETED, THE COMPLIANCE DEPARTMENT'S VERIFICATION THAT THE TRAINING WAS COMPLETED PERSONALLY BY VANECH, AND WHETHER A CORRESPONDING TRAINING ATTESTATION WAS LOCATED IN VANECH'S PERSONNEL FILE. Summary: TWO YEARS AFTER THE DATE OF ENTRY OF THE ORDER, VANECH WILL SUBMIT AN AFFIDAVIT STATING THAT HE HAS FULLY COMPLIED WITH ALL CONDITIONS OF THE ORDER. REGISTRATION CONDITIONS APPLIED TO VANECH'S AGENT REGISTRATION IN MASSACHUSETTS DUE TO DISCLOSURES
Allegations: THE ENFORCEMENT SECTION OF THE MISSOURI SECURITIES DIVISION ALLEGES AN ACTION THAT CONSTITUTES SUFFICIENT GROUNDS TO DISCIPLINE RESPONDENT IN ACCORDANCE WITH SECTIONS 409.4-412(B) AND (C). Status: Final Sanction Detail: SUSPENSION IN ALL CAPACITIES FOR 3 MONTHS 3 DAYS. SUSPENSION START DATE: 3/28/2024. SUSPENSION END DATE: 7/1/2024. CONSENT ORDER WAS ISSUED ON 3/28/2024 AND MONETARY FINE WAS PAID IN FULL AS OF 3/28/2024. Summary: THE ENFORCEMENT SECTION OF THE MISSOURI SECURITIES DIVISION ALLEGES AN ACTION THAT CONSTITUTES SUFFICIENT GROUNDS TO DISCIPLINE RESPONDENT IN ACCORDANCE WITH SECTIONS 409.4-412(B) AND (C). SUSPENSION IN ALL CAPACITIES FOR 3 MONTHS 3 DAYS. SUSPENSION START DATE: 3/28/2024. SUSPENSION END DATE: 7/1/2024. CONSENT ORDER WAS ISSUED ON 3/28/2024 AND $4,000 MONETARY FINE WAS PAID IN FULL AS OF 3/28/2024.
Allegations: SEC ADMIN RELEASE 34-73509, NOVEMBER 3, 2014: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST OPPENHEIMER & CO., INC. ("OPPENHEIMER" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B), 15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT: THESE PROCEEDINGS INVOLVE THE SALE OF NON-INVESTMENT GRADE OR "JUNK" BONDS ISSUED BY THE COMMONWEALTH OF PUERTO RICO ("PUERTO RICO") BY OPPENHEIMER, A REGISTERED BROKER-DEALER AND MUNICIPAL SECURITIES DEALER, TO CUSTOMERS IN AMOUNTS BELOW THE MINIMUM DENOMINATION OF THE ISSUE. RULE G-15(F) PROMULGATED BY THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") PROHIBITS DEALERS FROM EFFECTING CUSTOMER TRANSACTIONS IN MUNICIPAL SECURITIES IN AMOUNTS BELOW THE MINIMUM DENOMINATIONS OF THE ISSUES. MINIMUM DENOMINATIONS ARE GENERALLY INTENDED TO LIMIT SALES OF MUNICIPAL SECURITIES TO RETAIL CUSTOMERS FOR WHOM SUCH BONDS MAY NOT BE SUITABLE, BUT THE PROSCRIPTIONS OF RULE G-15(F) APPLY TO ALL TRANSACTIONS WITH CUSTOMERS, REGARDLESS OF WHETHER THE SECURITIES ARE SUITABLE FOR THE CUSTOMER. IN MARCH 2014, OPPENHEIMER VIOLATED MSRB RULE G-15(F) BY EXECUTING THREE UNSOLICITED SALES TRANSACTIONS IN THE PUERTO RICO BONDS WITH CUSTOMERS IN AMOUNTS BELOW THE $100,000 MINIMUM DENOMINATION OF THE ISSUE ESTABLISHED BY THE ISSUER, PUERTO RICO, AND SPECIFIED IN THE OFFICIAL STATEMENT. THE LIMITED EXCEPTIONS PROVIDED UNDER MSRB RULE G-15(F) FOR CUSTOMER TRANSACTIONS IN MUNICIPAL SECURITIES BELOW THE MINIMUM DENOMINATION OF AN ISSUE DID NOT APPLY TO THESE TRANSACTIONS. RESPONDENT DID NOT HAVE ANY POLICIES OR PROCEDURES CONCERNING MSRB RULE G-15(F). AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED MSRB RULE G-15(F). AS A RESULT OF RESPONDENT'S WILLFUL VIOLATIONS OF MSRB RULE G-15(F), RESPONDENT WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. Status: Final Sanction Detail: ACCORDINGLY, IT IS HEREBY ORDERED THAT: RESPONDENT CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT AND MSRB RULE G-15(F) . RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN SEVEN (7) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $61,200. RESPONDENT WILLFULLY VIOLATED MSRB RULE G-15(F). AS A RESULT OF RESPONDENT'S WILLFUL VIOLATIONS OF MSRB RULE G-15(F), RESPONDENT WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT. Summary: IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY RESPONDENT. AFTER IT WAS MADE AWARE THAT IT HAD EFFECTED CUSTOMER TRANSACTIONS IN THE 2014 BONDS BELOW THE MINIMUM DENOMINATION OF THE ISSUE, RESPONDENT CANCELLED THE TRANSACTIONS. RESPONDENT WILL UNDERTAKE TO REVIEW THE ADEQUACY OF ITS EXISTING POLICIES AND PROCEDURES RELATING TO COMPLIANCE WITH MSRB RULE G-15(F). AFTER THAT REVIEW, RESPONDENT WILL MAKE SUCH CHANGES AS ARE NECESSARY TO EFFECT COMPLIANCE WITH MSRB RULE G-15(F), INCLUDING ADOPTING NEW POLICIES AND PROCEDURES OR SUPPLEMENTING EXISTING POLICIES AND PROCEDURES. RESPONDENT WILL IMPLEMENT THESE POLICIES AND PROCEDURES, AND CONDUCT TRAINING AS TO THE POLICIES AND PROCEDURES AND COMPLIANCE WITH MSRB RULE G-15(F). RESPONDENT WILL INFORM COMMISSION STAFF NO LATER THAN SIX (6) MONTHS AFTER THE ENTRY OF THIS ORDER THAT IT HAS COMPLIED WITH THE ABOVE UNDERTAKINGS.
Allegations: SEC ADMIN RELEASES 33-9711 AND 34-74141, AND ACCOUNTING AND AUDITING ENFORCEMENT RELEASE 3621 / JANUARY 27, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST OPPENHEIMER & CO. INC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, OPPENHEIMER HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. OPPENHEIMER ADMITS THE COMMISSION'S JURISDICTION OVER IT AND OVER THE SUBJECT MATTER OF THESE PROCEEDINGS, ADMITS THE FACTS, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT: OPPENHEIMER ENGAGED IN TWO SEPARATE COURSES OF CONDUCT, EACH OF WHICH VIOLATED THE FEDERAL SECURITIES LAWS. OPPENHEIMER I: BETWEEN JULY 2008 AND MAY 2009, OPPENHEIMER EXECUTED SALES OF BILLIONS OF SHARES OF PENNY STOCKS FOR AN ACCOUNT IN THE NAME OF ITS CUSTOMER, A BROKER-DEALER LICENSED IN THE BAHAMAS. ALTHOUGH THE CUSTOMER PURPORTEDLY MAINTAINED A PROPRIETARY ACCOUNT, OPPENHEIMER KNEW THAT THE CUSTOMER WAS ACTUALLY EXECUTING TRANSACTIONS AND PROVIDING BROKERAGE SERVICES FOR ITS CUSTOMERS, MANY OF WHOM WERE U.S. PERSONS. THROUGH THIS CONDUCT, THE CUSTOMER ACTED AS A BROKER IN THE UNITED STATES EVEN THOUGH IT WAS NOT REGISTERED WITH THE COMMISSION AS REQUIRED BY THE FEDERAL SECURITIES LAWS. THE CUSTOMER PROVIDED OPPENHEIMER WITH AN IRS FORM W-8BEN, WHICH PURPORTEDLY EXEMPTED IT FROM U.S. TAX WITHHOLDING BASED ON A FALSE CERTIFICATION THAT IT WAS THE SOLE OWNER OF ALL OF THE INCOME GENERATED IN ITS OPPENHEIMER ACCOUNT. OPPENHEIMER, HOWEVER, KNEW THAT THE CUSTOMER'S CUSTOMERS (AND NOT IT) WERE THE BENEFICIAL OWNERS OF THE SECURITIES DEPOSITED, SOLD AND OR TRANSFERRED. AS A RESULT OPPENHEIMER KNEW OR SHOULD HAVE KNOWN THAT THE CUSTOMER'S IRS WITHHOLDING FORM WAS FALSE AND COULD NOT BE RELIED ON. THUS, OPPENHEIMER FAILED TO PROPERLY WITHHOLD AND REMIT TAXES TO THE IRS, AND THEREFORE BECAME LIABLE FOR TAXES IT WAS OBLIGATED TO WITHHOLD. OPPENHEIMER, HOWEVER, FAILED TO RECORD THIS LIABILITY AND RESULTING EXPENSES, WHICH CAUSED ITS BOOKS AND RECORDS TO BECOME INACCURATE. OPPENHEIMER'S RECORDS WERE ALSO INACCURATE BECAUSE THEY REFLECTED THE ACCOUNT IN WHICH THE CUSTOMER'S CUSTOMERS' SHARES WERE DEPOSITED, SOLD AND TRANSFERRED AS A PROPRIETARY ACCOUNT OF THE CUSTOMER, RATHER THAN AN ACCOUNT FOR THE CUSTOMER'S CUSTOMERS. IN INSTANCES WHEN SUSPICIOUS ACTIVITY OCCURRED IN THE CUSTOMER'S ACCOUNT, OPPENHEIMER FAILED TO FILE THE REQUISITE SUSPICIOUS ACTIVITY REPORTS. BY THESE CONDUCTS OPPENHEIMER WILLFULLY AIDED AND ABETTED AND WAS A CAUSE OF THE CUSTOMER'S VIOLATION OF SECTION 15(A) OF THE EXCHANGE ACT; VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-3(A)(2), 17A-3(A)(9); AND WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8. (CONT. IN COMMENT SECTION) 8. Status: Final Sanction Detail: THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(A) AND 17(A) OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-8 THEREUNDER AND OF SECTION 5 OF THE SECURITIES ACT; IS CENSURED; SHALL PAY TO THE COMMISSION $4,168,400 IN DISGORGEMENT; $753,471 IN PREJUDGMENT INTEREST; AND $5,078,129 IN CIVIL PENALTIES. THE FIRM SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER. Summary: (CONT. FROM ALLEGATIONS SECTION) OPPENHEIMER II: FROM OCTOBER 6, 2009 THROUGH DECEMBER 10, 2010, OPPENHEIMER, THROUGH A REGISTERED REPRESENTATIVE THEN ASSOCIATED WITH OPPENHEIMER AND HIS IMMEDIATE SUPERVISOR, WILLFULLY VIOLATED SECTIONS 5(A) AND (C) OF THE SECURITIES ACT WHEN IT ENGAGED IN THE UNREGISTERED DISTRIBUTION OF THE SECURITIES ON BEHALF OF A CUSTOMER. THE OVER 2.5 BILLION CUMULATIVE SHARES SOLD THROUGH THE CUSTOMER'S ACCOUNT GENERATED APPROXIMATELY $12,000,000 IN PROCEEDS OF WHICH OPPENHEIMER WAS PAID $588,400 IN COMMISSIONS. NO REGISTRATION STATEMENT WAS ON FILE OR IN EFFECT AS TO THE CUSTOMER'S OFFERS AND SALES OF SECURITIES AS REQUIRED BY SECTION 5 OF THE SECURITIES ACT. THE CUSTOMER'S OFFERS AND RE-SALES DID NOT COMPLY WITH RULE 144 OR QUALIFY FOR SECTION 4(A)(1) OR ANY OTHER EXEMPTION UNDER THE FEDERAL SECURITIES LAWS. AS A CONSEQUENCE, OPPENHEIMER WILLFULLY VIOLATED SECTIONS 5(A) AND (C) OF THE SECURITIES ACT. IN FAILING TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT AND DETECT OPPENHEIMER PERSONNEL'S VIOLATIONS OF SECTION 5, OPPENHEIMER ALSO FAILED REASONABLY TO SUPERVISE. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONS AGREED TO IN OPPENHEIMER'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT OPPENHEIMER: CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(A) AND 17(A) OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-8 THEREUNDER AND OF SECTION 5 OF THE SECURITIES ACT; IS CENSURED; SHALL PAY TO THE COMMISSION $10 MILLION COMPRISED OF $4,168,400 IN DISGORGEMENT; $753,471 IN PREJUDGMENT INTEREST; AND $5,078,129 IN CIVIL PENALTIES. THE FIRM SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER. A PENALTY AMOUNT THAT INCLUDES AN ADDITIONAL $10 MILLION IS APPROPRIATE FOR THE CONDUCT AT ISSUE HEREIN, HOWEVER, IN LIGHT OF THE CIVIL MONEY PENALTY PAID BY OPPENHEIMER TO THE U.S. TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK (FINCEN) IN IN THE MATTER OF OPPENHEIMER & CO. INC., NUMBER 2015-01, NO ADDITIONAL PENALTY IS BEING ORDERED AT THIS TIME. OPPENHEIMER'S TOTAL OBLIGATION TO PAY IN THIS PROCEEDING WOULD BE $20 MILLION IN THE EVENT IT FAILS TO PAY ITS $10 MILLION OF A CIVIL MONEY PENALTY TO FINCEN. PAYMENT OF DISGORGEMENT, PREJUDGMENT INTEREST, AND $78,129 IN CIVIL PENALTIES WILL BE DUE TEN (10) DAYS AFTER INSTITUTION OF THIS ORDER, WITH THE REMAINING $5,000,000 IN CIVIL PENALTIES, AND INTEREST ACCRUED PURSUANT TO 31 U.S.C. 3717, DUE NO LATER THAN THE SECOND ANNIVERSARY OF THE INSTITUTION OF THIS ORDER. THE COMMISSION ACKNOWLEDGES THAT OPPENHEIMER HAS PLACED CERTAIN ASSETS IN ESCROW WHICH OPPENHEIMER BELIEVES WILL SATISFY THE PAYMENT REQUIRED TO BE MADE BY THE SECOND ANNIVERSARY OF THE INSTITUTION OF THIS ORDER; HOWEVER, OPPENHEIMER RETAINS ITS PAYMENT OBLIGATION IRRESPECTIVE OF ANY AMOUNTS REALIZED BY PAYMENT FROM, SALE OF, OR REDEMPTION OF, ANY ESCROWED ASSETS.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT THE CORRECT TIME OF TRADE EXECUTIONS FOR TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIZED PRODUCTS AND FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDA OF BROKERAGE ORDERS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $10,000
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO MONITOR, SUPERVISE, AND CONTROL ITS EXTENSION OF MARGIN LOANS FOR FOREIGN SOVEREIGN DEBT. THE FINDINGS STATED THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT ADDRESS HOW TO ASSESS THE RISKS OF EXTENDING MARGIN CREDIT FOR FOREIGN SOVEREIGN BONDS. THE FIRM FAILED TO DEDICATE SUFFICIENT SUPERVISORY RESOURCES TO MONITORING THE RISK OF HOLDING BELOW-INVESTMENT-GRADE FOREIGN SOVEREIGN BONDS AND FAILED TO TAKE SUFFICIENT STEPS TO ASSESS WHETHER A READY MARKET EXISTED FOR BELOW-INVESTMENT-GRADE FOREIGN SOVEREIGN BONDS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE TRANSFER OF ASSETS SECURING A MARGIN LOAN FROM ONE PARTY TO ANOTHER. Status: Final Sanction Detail: THE FIRM IS CENSURED AND FINED $250,000.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUPERVISE ITS REGISTERED REPRESENTATIVE WHO MISAPPROPRIATED FUNDS FROM HIS CUSTOMERS AND EXCESSIVELY TRADED THEIR ACCOUNT. FINRA BARRED THE REPRESENTATIVE FOR, AMONG OTHER THINGS, STEALING APPROXIMATELY $6 MILLION FROM HIS CUSTOMERS AND EXCESSIVELY TRADING AND CHURNING HIS CUSTOMERS' ACCOUNTS, IN WILLFUL VIOLATION OF SECTION 10(B) OF THE SECURITIES EXCHANGE ACT AND RULE 10B-5 THEREUNDER. THE FINDINGS STATED THAT THE FIRM FAILED TO CONDUCT AN ADEQUATE PRE-HIRE INVESTIGATION OF THE REPRESENTATIVE AND FAILED TO PLACE HIM ON HEIGHTENED SUPERVISION. THE FIRM FAILED TO INVESTIGATE THE CIRCUMSTANCES OF THE TWELVE DISCLOSURES THAT APPEARED IN HIS CRD RECORD OR SUBJECT HIM TO HEIGHTENED SUPERVISION. WHEN THE REPRESENTATIVE JOINED THE FIRM, HIS CRD RECORD REPORTABLE EVENTS INCLUDED CRIMINAL CHARGES INVOLVING LARCENY OR POSSESSION OF STOLEN PROPERTY, A TERMINATION FOR CAUSE, A NEW YORK STOCK EXCHANGE INVESTIGATION, A PERSONAL BANKRUPTCY, AND CUSTOMER COMPLAINTS THAT WITH ALLEGED UNAUTHORIZED TRADING. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO SUPERVISE THE REPRESENTATIVE. THE FIRM WAS MADE AWARE THAT HE WAS ENGAGED IN UNDISCLOSED OUTSIDE BUSINESS ACTIVITIES, AND FAILED TO MONITOR OR IDENTIFY NUMEROUS RED FLAGS DEMONSTRATING THAT HE AND/OR ITS CUSTOMERS WERE WIRING CUSTOMER FUNDS TO ACCOUNTS HE CONTROLLED. THE FIRM FAILED TO PLACE HIM ON HEIGHTENED SUPERVISION AFTER IT BECAME AWARE OF SERIOUS ALLEGATIONS OF FRAUD AND DECEIT THAT HE SETTLED FOR $3 MILLION. THE FIRM FAILED TO TAKE ACTION TO RESTRICT HIS TRADING IN CUSTOMER ACCOUNTS AFTER ITS INTERNAL ANALYSIS SHOWED THAT HE WAS TRADING MULTIPLE CUSTOMER ACCOUNTS AT LEVELS CONSIDERED PRESUMPTIVELY EXCESSIVE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO MAINTAIN POLICIES AND PROCEDURES CAPABLE OF DETECTING AND PREVENTING CERTAIN POTENTIALLY FRAUDULENT THIRD PARTY WIRES, INCLUDING WIRES BETWEEN ITS CUSTOMERS' ACCOUNTS AND ITS REGISTERED REPRESENTATIVES OR THEIR OUTSIDE BUSINESS ACTIVITIES. FINRA FOUND THAT FOR OVER THREE YEARS THE FIRM'S PROCEDURES RELATED TO EXCESSIVE TRADING WERE UNREASONABLE BECAUSE THEY DID NOT PROVIDE FOR SPECIFIC ACTION TO BE TAKEN WHEN TRADING ACTIVITY WAS UNSUITABLE FOR ANY CUSTOMER OR WHEN CUSTOMER ACCOUNTS REPEATEDLY TRIGGERED THE FIRM'S EXCEPTION REPORTS. THE FIRM'S INADEQUATE PROCEDURES RELATED TO EXCESSIVE TRADING CONTRIBUTED TO ITS FAILURE TO REASONABLY SUPERVISE ITS REPRESENTATIVE. FINRA ALSO FOUND THAT THE FIRM, THROUGH ITS LEGAL DEPARTMENT, FAILED TO TIMELY MAKE 320 REQUIRED UPDATES RELATED TO ARBITRATIONS AND OTHER LEGAL MATTERS ON FORMS U4 AND U5 FILINGS. AS A RESULT, REGULATORS, THE INVESTING PUBLIC, AND OTHER MEMBER FIRMS WERE UNAWARE OF SERIOUS ALLEGATIONS MADE AGAINST THE FIRM'S CURRENT AND FORMER REGISTERED REPRESENTATIVES, INCLUDING THIS PARTICULAR REPRESENTATIVE. MOREOVER, PERSONNEL IN THE FIRM'S LEGAL DEPARTMENT WERE AWARE THAT THE DEPARTMENT WAS NOT MAKING TIMELY FILINGS. THE FIRM'S LEGAL DEPARTMENT ALSO CONTINUED TO FAIL TO MAKE CERTAIN REQUIRED FILINGS EVEN AFTER IT WAS PUT ON NOTICE OF THE NECESSITY OF MAKING SPECIFIC FILINGS BY FINRA. THE FIRM FAILED TO MAINTAIN OR IMPLEMENT SUPERVISORY PROCEDURES RELATED TO FILING U4 AND U5 AMENDMENTS. IN ADDITION, FINRA DETERMINED THAT THE FIRM FAILED TO TIMELY RESPOND TO FINRA'S REQUESTS FOR DOCUMENTS AND INFORMATION RELATED TO THE REPRESENTATIVE AND THE FIRM'S SUPERVISION OF THE REPRESENTATIVE. MOREOVER, FINRA FOUND THAT THE FIRM FAILED TO MAINTAIN IN A READILY ACCESSIBLE FORMAT ITS RECORDS OF ITS SUPERVISORS' REVIEWS OF THE REPRESENTATIVE'S EMAILED CORRESPONDENCE. AS A RESULT, THE FIRM FAILED TO PRODUCE RECORDS REFLECTING THE SUPERVISORY REVIEW OF ITS REPRESENTATIVE'S EMAILS UNTIL MORE THAN TWO YEARS AFTER THEY WERE ORIGINALLY REQUESTED BY FINRA, AND AFTER ORIGINALLY REPRESENTING TO FINRA THAT IT DID NOT MAINTAIN THE RECORDS. Status: Final Sanction Detail: THE FIRM IS CENSURED, FINED $2,500,000, ORDERED TO PAY $1,251,076.10 IN RESTITUTION TO CUSTOMERS AND REQUIRED TO RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S SUPERVISORY POLICIES, SYSTEMS AND PROCEDURES (WRITTEN AND OTHERWISE) AND TRAINING RELATING TO WIRE TRANSFERS, FORM U4/U5 REPORTING, AND EXCESSIVE TRADING
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT, IN TRANSACTIONS FOR OR WITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS. THESE VIOLATIONS RESULTED IN A TOTAL OF $109.15 IN RESTITUTION, WHICH THE FIRM HAS CONFIRMED WAS PAID. THE FINDINGS STATED THAT THE FIRM FAILED TO ACCURATELY REPORT THE CORRECT EXECUTION PRICE TO THE OVER-THE-COUNTER REPORTING FACILITY (OTCRF) AND FAILED TO SHOW THE CORRECT ORDER RECEIPT TIME AND TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASD AND FINRA RULES PERTAINING TO THE FIRM'S BEST EXECUTION OBLIGATIONS IN OTC SECURITIES. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $21,000.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CALL DATE AND DOLLAR PRICE OF THE CALL IN TRANSACTIONS IN MUNICIPAL SECURITIES EXECUTED ON THE BASIS OF A YIELD TO CALL. THE FINDINGS STATED THAT THE FIRM ALSO FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT NEXT POTENTIAL CALL DATE IN TRANSACTIONS IN CONTINUOUSLY CALLABLE MUNICIPAL SECURITIES EXECUTED ON THE BASIS OF A YIELD TO CALL. THE FINDINGS ALSO STATED THAT THE FIRM PROVIDED WRITTEN NOTIFICATION IMPROPERLY DISCLOSING TO ITS CUSTOMER A YIELD TO CALL IN TRANSACTIONS IN MUNICIPAL SECURITIES WITH A VARIABLE INTEREST RATE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWEST EFFECTIVE YIELD IN A TRANSACTION IN A MUNICIPAL SECURITY. FINRA FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS AND REGULATIONS, AND MSRB RULES, CONCERNING CUSTOMER CONFIRMATIONS FOR MUNICIPAL SECURITIES TRANSACTIONS. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $15,000, AND IS REQUIRED TO REVISE ITS WSPS.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERE NOT SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGS STATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $200,000 AND MUST OFFER RESCISSION TO THE CUSTOMERS WHO PURCHASED SECURITIES AT EITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR OVER FOUR YEARS, IT FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLY-DESIGNED SUPERVISORY SYSTEM AND WSPS REGARDING THE SALES OF LEVERAGED, INVERSE, AND INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONAL ETFS). THE FINDINGS STATED THAT IN RESPONSE TO FINRA'S REGULATORY NOTICE 09-31, THE FIRM INSTITUTED WSPS THAT PROHIBITED REPRESENTATIVES FROM SOLICITING RETAIL CUSTOMERS TO PURCHASE NON-TRADITIONAL ETFS. THE WSPS PERMITTED UNSOLICITED PURCHASES OF NON-TRADITIONAL ETFS BY RETAIL CUSTOMERS, BUT ONLY IF THE CUSTOMER WAS "PRE-QUALIFIED." TO MEET THIS PRE-QUALIFICATION REQUIREMENT, THE FIRM'S WSPS REQUIRED THAT REPRESENTATIVES OBTAIN A "LEVERAGED ETF REPRESENTATION LETTER" (THE "ETF QUALIFICATION LETTER") FROM EACH CUSTOMER SEEKING TO PURCHASE A NON-TRADITIONAL ETF. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ENFORCE ITS WSPS PROHIBITING THE SOLICITATION OF NON-TRADITIONAL ETF PURCHASES FOR RETAIL CUSTOMERS IN SEVERAL RESPECTS. FIRST, THE FIRM DID NOT ADEQUATELY TRAIN ITS SUPERVISORS AND REGISTERED REPRESENTATIVES ON THE PROHIBITION AGAINST SOLICITED NON-TRADITIONAL ETF PURCHASES. SECOND, THE FIRM DID NOT PREVENT REPRESENTATIVES AND THE TRADING DESK FROM ENTERING SOLICITED NON-TRADITIONAL ETF TRADES IN THE FIRM'S ORDER-ENTRY SYSTEM. THIRD, THE FIRM DID NOT USE AN EFFECTIVE SURVEILLANCE REPORT TO IDENTIFY SOLICITED NON-TRADITIONAL ETF TRADES. AS A RESULT, THE FIRM'S REPRESENTATIVES CONTINUED TO SOLICIT NON-TRADITIONAL ETF PURCHASES FROM RETAIL CUSTOMERS IN VIOLATION OF THE FIRM'S POLICIES. THE FIRM ALSO FAILED TO ENFORCE ITS WSPS BY ALLOWING RETAIL CUSTOMERS TO MAKE UNSOLICITED NON-TRADITIONAL ETF PURCHASES EVEN THOUGH THE CUSTOMERS WERE NOT PRE-QUALIFIED, EITHER BECAUSE THEY DID NOT HAVE AN ETF QUALIFICATION LETTER ON FILE OR BECAUSE THEY FAILED TO MEET THE PRE-QUALIFICATION CRITERIA SET FORTH IN THE ETF QUALIFICATION LETTER. AS A RESULT, UNSOLICITED NON-TRADITIONAL ETF PURCHASES CONTINUED TO BE EXECUTED FOR CUSTOMERS WHO WERE NOT PRE-QUALIFIED IN VIOLATION OF THE FIRM'S POLICIES. THE FINDINGS ALSO INCLUDED THAT THE FIRM DID NOT ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING THE USE OF EXCEPTION REPORTS, TO EFFECTIVELY MONITOR HOLDING PERIODS FOR NON-TRADITIONAL ETFS. A PRIMARY RISK WITH NON-TRADITIONAL ETFS IS THAT THEIR PERFORMANCE OVER LONGER PERIODS OF TIME CAN DIFFER SIGNIFICANTLY FROM THE PERFORMANCE OF THEIR UNDERLYING INDEX OR BENCHMARK, PARTICULARLY IN VOLATILE MARKETS. THE FIRM'S FAILURE TO HAVE AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR HOLDING PERIODS FOR NON-TRADITIONAL ETFS CONTRIBUTED TO CUSTOMER LOSSES. FINRA FOUND THAT ALTHOUGH THE FIRM'S WSPS PROHIBITED SOLICITATION OF NON-TRADITIONAL ETFS, ITS REPRESENTATIVES NONETHELESS CONTINUED TO OFFER THESE SECURITIES TO RETAIL CUSTOMERS. BEFORE DOING SO, THE FIRM DID NOT PERFORM AN ADEQUATE REASONABLE BASIS SUITABILITY ANALYSIS OF NON-TRADITIONAL ETFS TO UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH NON-TRADITIONAL ETFS. THE FIRM REPRESENTATIVES SOLICITED AND EFFECTED NON-TRADITIONAL ETF PURCHASES THAT WERE UNSUITABLE FOR SPECIFIC CUSTOMERS. CERTAIN OF THE FIRM'S REPRESENTATIVES RECOMMENDED THESE COMPLEX AND SPECULATIVE PRODUCTS TO NUMEROUS CUSTOMERS WITH CONSERVATIVE INVESTMENT OBJECTIVES, CERTAIN OF WHOM WERE ELDERLY. MOREOVER, SOME OF THESE CUSTOMERS HELD NON-TRADITIONAL ETF POSITIONS FOR EXTENDED PERIODS OF TIME - OFTEN MONTHS AND SOMETIME YEARS. FOR EXAMPLES, AN 89-YEAR CONSERVATIVE CUSTOMER WITH ANNUAL INCOME OF $50,000 HELD 96 SOLICITED NON-TRADITIONAL ETF POSITIONS FOR AN AVERAGE OF 32 DAYS (AND FOR UP TO 470 DAYS) FOR A NET LOSS OF $51,847. ALSO, A 91-YEAR CONSERVATIVE CUSTOMER WITH AN ANNUAL INCOME OF $30,000 HELD 56 SOLICITED NON-TRADITIONAL ETF POSITIONS FOR AN AVERAGE OF 48 DAYS (AND FOR UP TO 706 DAYS) FOR A NET LOSS OF $11,161. (CONTINUE IN COMMENT) Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $2,250,000, AND ORDERED TO PAY $716,831.80, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. Summary: CONTINUE FROM ALLEGATIONS SECTION)- ADDITIONALLY, A 67-YEAR CONSERVATIVE CUSTOMER WITH AN ANNUAL INCOME OF $40,000 HELD TWO SOLICITED NON-TRADITIONAL ETF POSITIONS IN HER ACCOUNT FOR 729 DAYS FOR A LOSS OF $2,746.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT SHORT INTEREST POSITIONS ON MULTIPLE SETTLEMENT DATES, AND INACCURATELY REPORTED SHORT POSITIONS. THE FINDINGS STATED THAT THE FIRM ERRONEOUSLY REPORTED "FAIL TO RECEIVE" POSITIONS ON MULTIPLE SETTLEMENT DATES IN THE FIRM'S "BUY-IN ACCOUNT" AS SHORT INTEREST POSITIONS, WHEN SUCH POSITIONS SHOULD NOT HAVE BEEN REPORTED TO FINRA. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND NASD AND FINRA RULES CONCERNING SHORT INTEREST REPORTING TO ENSURE COMPLIANCE WITH NASD RULE 3360 AND FINRA RULE 4560. IN ADDITION, WHILE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES IDENTIFIED AN INDIVIDUAL RESPONSIBLE FOR CONDUCTING A REVIEW, THE FREQUENCY OF SUCH REVIEW, AND A DESCRIPTION OF HOW THE REVIEW SHOULD BE DOCUMENTED, THE FIRM'S SUPERVISORY STEPS DID NOT CONTAIN A PERIODIC REVIEW OF THE FIRM'S SHORT INTEREST REPORTING LOGIC TO ASCERTAIN THAT IT WAS OPERATING PROPERLY AND THAT IT CAPTURED THE REQUIRED INFORMATION. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $275,000 AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT OVER THE COURSE OF SEVERAL YEARS, IT FAILED TO ESTABLISH, MAINTAIN, AND IMPLEMENT SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN SECURITIES REGULATIONS AND FINRA AND NASD RULES, AND TO REPORT VIOLATIONS OF THOSE RULES TO FINRA WHERE APPROPRIATE. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT REQUIRED INFORMATION TO FINRA, APPLY APPLICABLE SALES CHARGE WAIVERS TO ITS CUSTOMERS, AND PRODUCE RELEVANT DOCUMENTS TO CUSTOMERS WHO HAD FILED ARBITRATIONS AGAINST IT FOR FAILING TO SUPERVISE A FORMER REGISTERED REPRESENTATIVE. THE FINDINGS ALSO STATED THAT IN PARTICULAR, THE FIRM FAILED TO TIMELY MAKE 365 REQUIRED FILINGS WITH FINRA PURSUANT TO FINRA RULE 4530 AND ITS PREDECESSOR RULES, TO REPORT, AMONG OTHER THINGS, REGULATORY FINDINGS OF SECURITIES LAWS VIOLATIONS, DISCIPLINARY ACTIONS TAKEN BY THE FIRM AGAINST ITS EMPLOYEES, SETTLEMENTS OF SECURITIES-RELATED ARBITRATION AND LITIGATION CLAIMS, AND THE INSTITUTION OF SECURITIES-RELATED CIVIL LITIGATION AGAINST THE FIRM. THE FIRM DID NOT MAINTAIN PROCEDURES THAT GAVE DIRECTION TO THE FIRM'S EMPLOYEES ON MAKING THE DISCLOSURES REQUIRED BY FINRA RULES 4530(A), (B), AND (F). THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO TIMELY FILE REQUIRED FORM U4 AMENDMENTS DISCLOSING THAT TWO OF ITS EMPLOYEES HAD RECEIVED WELLS NOTICES FROM THE SECURITIES AND EXCHANGE COMMISSION. ALTHOUGH THE FIRM HAD IMPLEMENTED REVISED REPORTING PROCEDURES AS A RESULT OF A FINRA INVESTIGATION THAT SUBSEQUENTLY RESULTED IN A PREVIOUS LETTER OF ACCEPTANCE, WAIVER, AND CONSENT, IT FAILED TO IMPLEMENT PROCEDURES THAT ADEQUATELY ADDRESSED ITS SEPARATE REPORTING OBLIGATIONS PURSUANT TO FINRA RULES 4530 (A), (B), AND (F), AND ITS OBLIGATION TO REPORT REGULATORY EVENTS ON FORMS U4. THE FIRM FAILED TO MAINTAIN ADEQUATE WRITTEN PROCEDURES TO ENSURE THAT REGULATORY EVENTS, INCLUDING WELLS NOTICES, WERE REPORTED ON FORMS U4 AND U5. ALL OF THE FIRM'S SUPERVISORY AND COMPLIANCE PROCEDURES FAILED TO SPECIFICALLY ADDRESS REPORTING REGULATORY EVENTS, INCLUDING WELLS NOTICES. AS A RESULT OF THE FIRM'S INADEQUATE PROCEDURES, EMPLOYEES IN ITS VARIOUS DEPARTMENTS WERE UNCERTAIN OF THEIR INDIVIDUAL RESPONSIBILITY FOR ENSURING THAT REGULATORY EVENTS WERE DISCLOSED ON FORMS U4 AND U5. FINRA FOUND THAT THE FIRM DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS). THESE ELIGIBLE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. DURING THE PERIOD, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE ELIGIBLE CUSTOMERS RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO REASONABLY SUPERVISE THE APPLICATION OF SALES CHARGE WAIVERS TO ELIGIBLE MUTUAL FUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS, BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. IN ADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH IT DID NOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. FINRA ALSO FOUND THAT THE FIRM FAILED TO PRODUCE CERTAIN RESPONSIVE DOCUMENTS TO SEVEN ARBITRATION CLAIMANTS WHO ALLEGED THAT THE FIRM FAILED TO SUPERVISE THE FORMER REGISTERED REPRESENTATIVE. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $1,575,000. REMEDIATION PAYMENTS TOTALING $703,122 TO BE PAID TO THE SEVEN SETS OF ARBITRATION CLAIMANTS, AND ADDITIONAL REMEDIATION TOTALING APPROXIMATELY $1,142,619 PAID TO THE ELIGIBLE CUSTOMERS WHO, FROM JANUARY 2009 TO AUGUST 2016, QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES CHARGE WAIVERS. THE FIRM IS REQUIRED TO CERTIFY TO FINRA ENFORCEMENT, WITHIN 90 DAYS OF THE ISSUANCE OF THE AWC THAT IT HAS ADOPTED AND IMPLEMENTED WRITTEN SUPERVISORY POLICIES AND PROCEDURES REASONABLY DESIGNED TO ADDRESS THE DEFICIENCIES IDENTIFIED IN THE AWC. Summary: THE FIRM SELF-REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. AS A RESULT OF THE FAILURE OF THE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY APPROXIMATELY $1,010,327 FOR MUTUAL FUND PURCHASES MADE. AS PART OF THIS SETTLEMENT, THE FIRM HAS PAID RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH IS ESTIMATED TO TOTAL $1,142,619 (I.E., THE AMOUNT ELIGIBLE CUSTOMERS WERE OVERCHARGED, INCLUSIVE OF INTEREST). THE FIRM WILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. SOLELY WITH RESPECT TO THE PORTION OF THIS MATTER THAT RELATES TO THE FIRM'S FAILURE TO PROVIDE SALES CHARGE WAIVERS, FINRA HAS RECOGNIZED THE COOPERATION OF THE FIRM FOR HAVING: INITIATED IN AUGUST 2015, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, AN INVESTIGATION TO IDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGE WAIVERS DURING THE RELEVANT PERIOD; PROMPTLY ESTABLISHED A PLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOT RECEIVE APPROPRIATE SALES CHARGE WAIVERS; PROMPTLY SELF-REPORTED TO FINRA; PROMPTLY TAKEN ACTION AND REMEDIAL STEPS TO CORRECT THE VIOLATIVE CONDUCT; AND EMPLOYED SUBSEQUENT CORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, TO REVISE ITS PROCEDURES TO AVOID RECURRENCE OF THE MISCONDUCT.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED ON 43 OCCASIONS TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CALL DATE AND DOLLAR PRICE OF THE CALL IN 43 TRANSACTIONS IN MUNICIPAL SECURITIES EXECUTED ON THE BASIS OF A YIELD TO CALL. THE FINDINGS STATED THAT THE FIRM FAILED ON THREE OCCASIONS TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWEST EFFECTIVE YIELD IN THREE TRANSACTIONS IN MUNICIPAL SECURITIES AND PROVIDED ON ONE OCCASION WRITTEN NOTIFICATION IMPROPERLY DISCLOSING TO ITS CUSTOMER A YIELD TO CALL IN ONE TRANSACTION IN A MUNICIPAL SECURITY WITH A VARIABLE INTEREST RATE. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $20,000.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN SIX TRANSACTIONS, IT PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARK-UP OR MARK-DOWN) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $20,000, AND ORDERED TO PAY $10,301.44, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.
Allegations: DURING THE PERIOD BETWEEN JANUARY 19, 2010 AND JUNE 30, 2015 (THE REVIEW PERIOD), THE FIRM OVER-REPORTED OPTIONS POSITIONS TO THE LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 260,890 INSTANCES BECAUSE OF A CODING ERROR IN ITS LOPR LOGIC THAT CAUSED: (I) RECORDS THAT WERE PROCESSED ON AN "AS OF" BASIS TO CLOSE A POSITION TO BE ERRONEOUSLY PROCESSED AS NEW OPENING POSITIONS RATHER THAN CLOSING POSITIONS; AND (II) DISPARATE REPORTING OF CANCELLATION AND REBOOKING ACTIVITY TO THE LOPR FOLLOWING TRADE CORRECTIONS. AS A RESULT, THE FIRM VIOLATED NASDAQ PHLX LLC (EXCHANGE) RULES 1003 AND 707. DURING THE REVIEW PERIOD, THE FIRM'S SUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM. ADDITIONALLY, DURING THE REVIEW PERIOD AND THROUGH MAY 2017, THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM. SPECIFICALLY, THEY FAILED TO SPECIFY: (I) WHAT REVIEWS THE FIRM CONDUCTED, INCLUDING THE STEPS TO BE TAKEN IN CONNECTION WITH SUCH REVIEWS, TO DETECT ISSUES RELATING TO THE FORMATTING OF ITS LOPR REPORT, ACTING-IN-CONCERT ACTIVITY, AND REJECTED LOPR SUBMISSIONS; (II) THE PERSON(S) RESPONSIBLE FOR CONDUCTING SUCH REVIEWS; (III) THE FREQUENCY OF SUCH REVIEWS; AND (IV) HOW THE REVIEWS ARE TO BE DOCUMENTED. AS A RESULT, THE FIRM VIOLATED EXCHANGE RULES 748(G) (FOR THE PERIOD PRIOR TO NOVEMBER 23, 2012), 748(H) (FOR THE PERIOD ON AND AFTER NOVEMBER 23, 2012), AND 707. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $75,000. Summary: THE FIRM MADE AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS, PURSUANT TO EXCHANGE RULE 960.7, SOLELY FOR THE PURPOSES OF THESE PROCEEDINGS AND TO SETTLE AND CONCLUDE ALL DISCIPLINARY ACTIONS BY THE EXCHANGE BASED ON OR ARISING OUT OF THE FACTS HEREINAFTER STIPULATED. THE FIRM STIPULATES TO THE FACTS, CONSENTS TO THE CONCLUSION OF VIOLATIONS OF CERTAIN PROVISIONS OF EXCHANGE RULES, AND CONSENTS TO THE IMPOSITION OF SANCTIONS SPECIFICALLY INCLUDING, BUT NOT LIMITED TO, CONSENTING TO PAY THE FINE IMPOSED BY THE BUSINESS CONDUCT COMMITTEE CONSISTENT WITH THE OFFER, AND TO COMPLY WITH ALL OTHER SANCTIONS, ALL AS HEREINAFTER SET FORTH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR CONCLUSIONS IN THE STATEMENT OF CHARGES. IN DETERMINING TO RESOLVE THIS MATTER, THE COMMITTEE TOOK INTO ACCOUNT THE FIRM'S ENSUING COOPERATION THROUGHOUT FINRA'S INVESTIGATION AND THE SUBSEQUENT REMEDIAL MEASURES IMPLEMENTED BY THE FIRM, INCLUDING SIGNIFICANT SYSTEM ENHANCEMENTS. (ASSOCIATED CASE NO. PHLX ENFORCEMENT 2017-14)
Allegations: DURING THE PERIOD BETWEEN JANUARY 19, 2010 AND JUNE 30, 2015 (THE REVIEW PERIOD), THE FIRM OVER-REPORTED OPTIONS POSITIONS TO THE LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 260,890 INSTANCES BECAUSE OF A CODING ERROR IN ITS LOPR LOGIC THAT CAUSED: (I) RECORDS THAT WERE PROCESSED ON AN "AS OF" BASIS TO CLOSE A POSITION TO BE ERRONEOUSLY PROCESSED AS NEW OPENING POSITIONS RATHER THAN CLOSING POSITIONS; AND (II) DISPARATE REPORTING OF CANCELLATION AND REBOOKING ACTIVITY TO THE LOPR FOLLOWING TRADE CORRECTIONS. AS A RESULT, THE FIRM VIOLATED CBOE (EXCHANGE) RULES 4.2, 4.24 AND 4.13. DURING THE REVIEW PERIOD, THE FIRM'S SUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM. ADDITIONALLY, DURING THE REVIEW PERIOD AND THROUGH MAY 2017, THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM. SPECIFICALLY, THEY FAILED TO SPECIFY: (I) WHAT REVIEWS THE FIRM CONDUCTED, INCLUDING THE STEPS TO BE TAKEN IN CONNECTION WITH SUCH REVIEWS, TO DETECT ISSUES RELATING TO THE FORMATTING OF ITS LOPR REPORT, ACTING-IN-CONCERT ACTIVITY, AND REJECTED LOPR SUBMISSIONS; (II) THE PERSON(S) RESPONSIBLE FOR CONDUCTING SUCH REVIEWS; (III) THE FREQUENCY OF SUCH REVIEWS; AND (IV) HOW THE REVIEWS ARE TO BE DOCUMENTED. AS A RESULT, THE FIRM VIOLATED EXCHANGE RULES 748(G) (FOR THE PERIOD PRIOR TO NOVEMBER 23, 2012), 748(H) (FOR THE PERIOD ON AND AFTER NOVEMBER 23, 2012), AND 707. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $625,000. Summary: THE FIRM MADE AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS, PURSUANT TO EXCHANGE RULE 4.13, SOLELY FOR THE PURPOSES OF THESE PROCEEDINGS AND TO SETTLE AND CONCLUDE ALL DISCIPLINARY ACTIONS BY THE EXCHANGE BASED ON OR ARISING OUT OF THE FACTS HEREINAFTER STIPULATED. THE FIRM STIPULATES TO THE FACTS, CONSENTS TO THE CONCLUSION OF VIOLATIONS OF CERTAIN PROVISIONS OF EXCHANGE RULES, AND CONSENTS TO THE IMPOSITION OF SANCTIONS SPECIFICALLY INCLUDING, BUT NOT LIMITED TO, CONSENTING TO PAY THE FINE IMPOSED BY THE BUSINESS CONDUCT COMMITTEE CONSISTENT WITH THE OFFER, AND TO COMPLY WITH ALL OTHER SANCTIONS, ALL AS HEREINAFTER SET FORTH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR CONCLUSIONS IN THE STATEMENT OF CHARGES. IN DETERMINING TO RESOLVE THIS MATTER, THE COMMITTEE TOOK INTO ACCOUNT THE FIRM'S ENSUING COOPERATION THROUGHOUT FINRA'S INVESTIGATION AND THE SUBSEQUENT REMEDIAL MEASURES IMPLEMENTED BY THE FIRM, INCLUDING SIGNIFICANT SYSTEM ENHANCEMENTS.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT NEGLIGENTLY MISREPRESENTED COST BASIS INFORMATION ON CUSTOMER ACCOUNT STATEMENTS AND FORMS 1099 AND MADE AND PRESERVED INACCURATE ACCOUNT STATEMENTS. THE FINDINGS STATED THAT THE INDIVIDUAL WHO SUPERVISED THE GROUP THAT OPERATED THE FIRM'S DATABASE SYSTEM IN WHICH IT MAINTAINED COST BASIS INFORMATION, AS WELL AS INFORMATION ABOUT THE TAXABLE GAIN OR LOSS RESULTING FROM ITS CUSTOMERS' SECURITIES TRANSACTIONS, DID NOT UNDERSTAND THE REGULATIONS APPLICABLE TO POST-SETTLEMENT COST BASIS CHANGES. AS A RESULT, THE FIRM REGULARLY GRANTED REQUESTS TO CHANGE COST BASIS INFORMATION IN THE CASE OF PARTIAL LIQUIDATIONS OF SECURITIES POSITIONS, EVEN WHEN REQUESTS TO CHANGE THE TAX LOT SOLD WERE MADE AFTER THE SETTLEMENT DATE. EACH SUCH INSTANCE RESULTED IN THE FIRM ISSUING AT LEAST ONE FORM 1099 IN WHICH IT MISREPRESENTED THE ADJUSTED BASIS AND ALSO RESULTED IN THE FIRM SENDING TO THE CUSTOMER ONE OR MORE MONTHLY ACCOUNT STATEMENTS IN WHICH IT MISREPORTED ADJUSTED BASIS AND RELATED REALIZED AND UNREALIZED GAIN OR LOSS INFORMATION. EMAILS AND DOCUMENTS PERTAINING TO THESE CHANGES, WHERE THEY EXIST, SHOWED THAT THE FIRM'S REGISTERED REPRESENTATIVES AND OTHER OPERATIONS PERSONNEL, FOR THE MOST PART, LIKEWISE LACKED A PROPER UNDERSTANDING OF THE REGULATIONS APPLICABLE TO POST-SETTLEMENT COST BASIS CHANGES. THE FIRM'S DATABASE SYSTEM THAT WAS SUPPOSED TO HAVE KEPT TRACK OF MANUAL CHANGES TO COST BASIS LACKED BASIC INFORMATION ABOUT COST BASIS CHANGES, INCLUDING THE REASON FOR THE CHANGES. THIS DATABASE SYSTEM ALSO CONTAINED FIELDS THAT COULD BE OVERWRITTEN AFTER THE DATE OF THE CHANGE. AS A RESULT, THERE WERE NUMEROUS INSTANCES IN WHICH INFORMATION CONCERNING MANUAL COST BASIS CHANGES HAD BEEN OVERWRITTEN AND COULD NOT BE RETRIEVED. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $525,000 AND REQUIRED TO RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS PROCEDURES, SYSTEMS, AND CONTROLS TO TRACK AND REPORT COST BASIS INFORMATION RELATING TO ANY UPDATES AND CHANGES MADE TO COST BASIS INFORMATION FOR CUSTOMER SECURITIES TRANSACTIONS.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ADHERE TO GOOD BUSINESS PRACTICES WITH RESPECT TO ITS HANDLING OF CUSTOMER OPTIONS ORDERS. THE FINDINGS STATED THAT BY INSTRUCTING AN NYSE AMERICAN FLOOR BROKER TO PREEMPTIVELY CROSS AND SELL CALLS AT $1.70 BEFORE THE STOCK REACHED THE LIQUIDITY PROVIDER'S CONTINGENT BID PRICE, A FIRM TRADER WAS ABLE TO AVOID COMPETITION FROM ON-FLOOR MARKET MAKERS IN THE TRADING CROWD. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO OBTAIN PRIOR AGREEMENT OF ITS CUSTOMER BEFORE NULLIFYING AND ADJUSTING A TRADE TO A WORSE PRICE FOR THE CUSTOMER. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ITS OBLIGATIONS FOR HANDLING CERTAIN CUSTOMER OPTIONS ORDERS TRANSMITTED TO A FLOOR BROKER ON THE NYSE AMERICAN TRADING FLOOR. THE FIRM DID NOT CONDUCT A REVIEW OF OPTIONS ORDERS SENT TO THE NYSE AMERICAN TRADING FLOOR WHERE AN EXECUTION WAS SUBSEQUENTLY NULLIFIED AND/OR ADJUSTED, AND SO DID NOT IDENTIFY TWO TRADES. NOR DID THE FIRM HAVE ANY POLICIES OR PROCEDURES IN PLACE REQUIRING EMPLOYEES TO OBTAIN PRIOR CUSTOMER AGREEMENT FOR PRICE ADJUSTMENTS. FINALLY, A DESK SUPERVISOR GAVE THE INSTRUCTIONS TO IMPROPERLY ADJUST THE PRICE ON A TRADE. FINRA FOUND THAT THE FIRM IMPLEMENTED NEW PROCEDURES REQUIRING OPTIONS DESK EMPLOYEES TO DOCUMENT AND NOTIFY COMPLIANCE OF ALL TRADE NULLIFICATIONS AND PRICE ADJUSTMENTS, AND TO OBTAIN PRIOR WRITTEN CUSTOMER AGREEMENT FOR ANY NULLIFIED OR ADJUSTED TRADES. THE FIRM ALSO NOW CONDUCTS A DAILY REVIEW OF A REPORT IDENTIFYING ALL TRADE AMENDMENTS, ADJUSTMENTS, AND CANCELLATIONS. IN CONNECTION WITH NYSE REGULATION'S INVESTIGATION, THE FIRM OFFERED THE CUSTOMER WHO WAS IMPACTED BY A TRADE RESTITUTION IN THE AMOUNT OF $11,160. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $175,000.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE ARCA RULE 11.1(B). THE FINDINGS STATED THAT THE FIRM FAILED TO OBTAIN THE MOST ADVANTAGEOUS TERMS FOR A CUSTOMER OPTIONS ORDER, AND ALSO FAILED TO OBTAIN THE AGREEMENT OF ITS CUSTOMER PRIOR TO INSTRUCTING THE FLOOR BROKER TO NULLIFY AND ADJUST THE TRADE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ITS OBLIGATIONS FOR CERTAIN CUSTOMER OPTIONS ORDERS. THE FIRM DID NOT HAVE POLICIES OR PROCEDURES IN PLACE REGARDING ITS OBLIGATIONS FOR THE HANDLING OF NOT-HELD ORDERS, INCLUDING WITH RESPECT TO TRADE NULLIFICATION. ACCORDINGLY, THE FIRM VIOLATED NYSE ARCA RULES 11.18(B) AND (C). Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $90,000. IN CONNECTION WITH NYSE REGULATION'S INVESTIGATION, THE FIRM OFFERED THE CUSTOMER RESTITUTION IN THE AMOUNT OF $25,400.
Allegations: OPPENHEIMER & CO. INC VIOLATED CBOE RULES 4.24 AND 8.16 IN THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE LOPR RULES. Status: Final Sanction Detail: A CENSURE, A MONETARY FINE IN THE AMOUNT OF $450,000 AND AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE TRANSACTIONS THAT ITS REGISTERED REPRESENTATIVES PLACED DIRECTLY WITH PRODUCT SPONSORS ON BEHALF OF FIRM CUSTOMERS (I.E., DIRECT BUSINESS TRANSACTIONS OR HELD AWAY SECURITIES TRANSACTIONS). THE FINDINGS STATED THAT THE FIRM DID NOT TAKE STEPS REASONABLY DESIGNED TO ENSURE THAT DIRECT BUSINESS TRANSACTIONS APPEARED ON THE FIRM'S DAILY TRADE BLOTTER, CAUSING THE FIRM TO FAIL TO RUN TRANSACTIONS, INCLUDING DIVIDEND REINVESTMENTS, FOR CUSTOMERS THROUGH EXCEPTION REPORTS USED TO IDENTIFY POTENTIAL SALES PRACTICE VIOLATIONS, INCLUDING POTENTIALLY UNSUITABLE TRANSACTIONS. THE FIRM ALSO FAILED TO ENSURE THAT IT COLLECTED INFORMATION FOR CUSTOMERS' INVESTMENT PROFILES, SUCH AS THE CUSTOMERS' AGES, INVESTMENT TIME HORIZONS, AND LIQUIDITY NEEDS, THAT WAS RELEVANT FOR MAKING CERTAIN SUITABILITY DETERMINATIONS. SUBSEQUENTLY, THE FIRM REVISED ITS WSPS TO PROHIBIT DIRECT TRANSACTIONS WITH MUTUAL FUND COMPANIES UNLESS A CORRESPONDING ACCOUNT HAS BEEN ESTABLISHED AT THE FIRM. THE FIRM ALSO INSTITUTED PROCEDURES TO VERIFY THAT EACH DIRECT BUSINESS MUTUAL FUND TRANSACTION IS HOUSED IN A FIRM ACCOUNT OR, IF NOT, TO REQUIRE REGISTERED REPRESENTATIVES TO PROMPTLY OBTAIN A NEW ACCOUNT APPLICATION AND OPEN AN ACCOUNT FOR THE CUSTOMER. THE FIRM ALSO ESTABLISHED PROGRESSIVE DISCIPLINE MEASURES IF REPRESENTATIVES FAILED TO OBTAIN NEW ACCOUNT APPLICATIONS. ULTIMATELY, THE FIRM BEGAN A RETROSPECTIVE REVIEW OF ITS DIRECT BUSINESS TRANSACTIONS DURING THE RELEVANT PERIOD. THAT REVIEW INVOLVED IDENTIFYING THE DIRECT BUSINESS TRANSACTIONS THAT THE FIRM FAILED TO INCLUDE ON ITS TRADE BLOTTER AND REVIEWING THE TRANSACTIONS ACCORDING TO THE PARAMETERS USED BY THE FIRM'S EXCEPTION REPORTING SYSTEM. THE FIRM ATTEMPTED TO COLLECT MISSING INFORMATION ABOUT CUSTOMERS' INVESTMENT PROFILES. THE SUITABILITY OF CERTAIN OF THE TRANSACTIONS COULD NOT BE DETERMINED BECAUSE THE FIRM WAS UNABLE TO COLLECT COMPLETE INFORMATION AT THE TIME OF THE RETROSPECTIVE REVIEW ABOUT CUSTOMERS' INVESTMENT PROFILES, INCLUDING THEIR INVESTMENT TIME HORIZONS OR LIQUIDITY NEEDS THAT WOULD HAVE BEEN RELEVANT AT THE TIME OF THE PURCHASE. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $500,000.
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO DISPLAY IMMEDIATELY 31 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY. THE CONDUCT VIOLATED SECURITIES EXCHANGE ACT OF 1934 RULE 604 OF REGULATION NMS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $7,500.
Allegations: THE SECURITIES DIVISION OF THE OFFICE OF THE ATTORNEY GENERAL FOR SOUTH CAROLINA DETERMINED THAT OPPENHEIMER, WITHOUT ADMITTING OR DENYING THE FINDINGS, FAILED TO DETECT AND REPORT THE ACTIVITIES OF MARK HOTTON (CRD# 2346843), A FORMER REGISTERED REPRESENTATIVE AND ONE OTHER, UNIDENTIFIED REPRESENTATIVE. THIS RELATES TO A RESIDENT OF SOUTH CAROLINA, AND HOTTON'S RECOMMENDATION THAT THE CLIENT INVEST IN PRIVATE INVESTMENTS FROM NOVEMBER 2005 THROUGH OCTOBER 2008. OPPENHEIMER PAID A FINE OF $150,000 AND REIMBURSED COSTS OF $25,000. Status: Final Sanction Detail: THE SECURITIES DIVISION OF THE OFFICE OF THE ATTORNEY GENERAL FOR SOUTH CAROLINA DETERMINED THAT OPPENHEIMER, WITHOUT ADMITTING OR DENYING THE FINDINGS, FAILED TO DETECT AND REPORT THE ACTIVITIES OF MARK HOTTON (CRD# 2346843), A FORMER REGISTERED REPRESENTATIVE AND ONE OTHER, UNIDENTIFIED REPRESENTATIVE. THIS RELATES TO A RESIDENT OF SOUTH CAROLINA, AND HOTTON'S RECOMMENDATION THAT THE CLIENT INVEST IN PRIVATE INVESTMENTS FROM NOVEMBER 2005 THROUGH OCTOBER 2008. OPPENHEIMER PAID A FINE OF $150,000 AND REIMBURSED COSTS OF $25,000.
Allegations: THE INVESTIGATION DETERMINED THAT RESPONDENT WAS RESPONSIBLE FOR SUBMITTING THE RELEVANT INVESTMENT ADVISER REPRESENTATIVE REGISTRATION APPLICATION MATERIALS FOR FORTY (40) MICHIGAN INDIVIDUAL REPRESENTATIVES, BUT THAT IT FAILED TO DO SO FROM THE EFFECTIVE DATE OF THE SECURITIES ACT ON OCTOBER 1, 2009 (AS EXTENDED BY VARIOUS TRANSITION ORDERS) THROUGH LATE 2015/EARLY 2016. RESPONDENT HAS NOT IDENTIFIED ANY EXEMPTION, EXCEPTION, PREEMPTION, OR EXCLUSION JUSTIFYING ITS FAILURE TO REGISTER THESE 40 INVESTMENT ADVISER REPRESENTATIVES IN MICHIGAN FROM OCTOBER 1, 2009 (THE DATE THE REGISTRATION REQUIREMENT BECAME EFFECTIVE) THROUGH THEIR ACTUAL REGISTRATION DATE IN LATE 2015/EARLY 2016. Status: Final Sanction Detail: CIVIL FINE- $900,000
Allegations: DELAWARE ALLEGES THAT THE FIRM VIOLATED 6DEL C 7316(A)(10) (2002) BY FAILING TO SUPERVISE AN FA AND FAILING TO COMPLY WITH CERTAIN ASPECTS OF ITS COMPLIANCE SYSTEM. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY WRONGDOING ON THE PART OF OPPENHEIMER OR ANY OF ITS AGENTS OR FORMER AGENTS, OPPENHEIMER AGREED TO PAY $685,000. TO THE DELAWARE INVESTOR PROTECTION FUND AND AGREED TO CERTAIN UNDERTAKINGS. OPPENHEIMER PAID THE PENALTY ON OR ABOUT JULY 2, 2015 AND WAS ORDERED TO REFRAIN FROM COMMITTING ANY FUTURE VIOLATIONS OF THE ACT. Summary: THE AFOREMENTIONED UNDERTAKINGS AGREED TO ARE AS FOLLOWS: OPPENHEIMER SHALL DEVELOP AND MAINTAIN POLICIES, PROCEDURES AND SYSTEMS THAT REASONABLY SUPERVISE THE ACTIVIITES OF ITS BROKER-DEALER AGENTS, INVESTMENT ADVISORS, AND BRANCH OFFICE MANAGERS, AND ENSURE FULL COMPLIANCE BY ITS OFFICERS, AGENTS, EMPLOYEES, AND REPRESENTATIVES WITH THEIR AND OPPENHEIMERS RESPONSIBILITIES TO THEIR CLIENTS.
Allegations: THE UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN") ALLEGED THAT OPPENHEIMER & CO. INC. ("OPPENHEIMER") WILLFULLY VIOLATED THE BANK SECRECY ACT BY (A) FAILING TO IMPLEMENT AND ADEQUATE ANTI-MONEY LAUNDERING PROGRAM, 31 U.S.C.S. 5318(H) AND 31 C.F.R.S. 1023.210;(B) FAILED TO IMPLEMENT AN ADEQUATE DUE DILIGENCE PROGRAM FOR A FOREIGN CORRESPONDENT ACCOUNT, 31 U.S.C.S. 5318(I)(1) AND 31C.F.R.S. 1023.610; AND (C) FAILED TO COMPLY WITH NOTIFICATION REQUIREMENTS UNDER RULES IMPOSING SPECIAL MEASURES UNDER SECTION 311 OF THE USA PATRIOT ACT AGAINST THREE FOREIGN FINANCIAL INSTITUTIONS OF PRIMARY MONEY LAUNDERING CONCERN. 31 CFRS. 1010.653, 1010.654, 1010.655. Status: Final Sanction Detail: OPPENHEIMER ADMITTED THAT IT VIOLATED THE BANK SECRECY ACT AND CONSENTED TO THE ASSESSMENT OF A CIVIL MONEY PENALTY IN THE AMOUNT OF $20 MILLION, OF WHICH $10 MILLION WAS CONCURRENT WITH THE PENALTY, DISGORGEMENT AND PREJUDGMENT INTEREST IMPOSED BY THE SEC IN CONNECTION WITH IN THE MATTER OF OPPENHEIMER & CO. INC., ADMINISTRATIVE PROCEEDING FILE NO. 3-16361 (JAN. 27, 2015). OPPENHEIMER PAID $5 MILLION OF THE $10 MILLION PENALTY TO FINCEN ON FEBRUARY 9, 2015 AND THE REMAINING $5 MILLION PENALTY IS DUE TO BE PAID TO FINCEN BY JANUARY 27, 2017.
Allegations: SEC ADMIN RELEASES 33-9836; 34-75230, JUNE 18, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST OPPENHEIMER & CO. INC. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE. OPPENHEIMER UNDERSTANDS THAT ON THE SAME DATE, THE SEC ANNOUNCED PUBLIC ADMINISTRATIVE AND CEASE AND DESIST PRECEEDINGS SIMILIAR TO THE ONE DISCLOSED HEREIN AGAINST THIRTY FIVE (35) OTHER UNDERWRITER BROKER/DEALERS. Status: Final Sanction Detail: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE
Allegations: SEC ADMIN RELEASE IA 5137, MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST OPPENHEIMER & CO. INC. AND ITS AFFILIATE OPPENHEIMER ASSET MANAGEMENT INC. (TOGETHER, "RESPONDENTS"). ON THE BASIS OF THIS ORDER AND RESPONDENTS' OFFERS, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENTS IN CONNECTION WITH THEIR MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENTS PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENTS RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENTS FAILED TO DISCLOSE IN THEIR FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) THEIR RECEIPT OF 12B-1 FEES, AND/OR (B) THEIR SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENTS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENTS WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. Status: Final Sanction Detail: THE RESPONDENTS SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENTS ARE CENSURED, SHALL, JOINTLY AND SEVERALLY, PAY DISGORGEMENT OF $3,169,123 AND PREJUDGMENT INTEREST OF $359,254, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: RESPONDENTS HAVE SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENTS' OFFERS. RESPONDENTS SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENTS' OFFERS ARE BASED ON THE INFORMATION SELF-REPORTED BY RESPONDENTS.
Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, AGAINST OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") THAT THE COMMISSION HAS DETERMINED TO ACCEPT. THE COMMISSION FINDS THAT OPPENHEIMER EMPLOYEES SENT AND RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF THE BROKER-DEALER. RESPONDENT DID NOT MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE WRITTEN COMMUNICATIONS. RESPONDENT'S FAILURE WAS FIRM-WIDE AND INVOLVED EMPLOYEES AT ALL LEVELS OF AUTHORITY. OPPENHEIMER'S SUPERVISORS, WHO WERE RESPONSIBLE FOR SUPERVISING JUNIOR EMPLOYEES, ROUTINELY COMMUNICATED OFF-CHANNEL USING THEIR PERSONAL DEVICES. IN FACT, SENIOR MANAGEMENT, MANAGING DIRECTORS, AND OTHER OPPENHEIMER EMPLOYEES ACROSS THE FIRM RESPONSIBLE FOR SUPERVISING JUNIOR EMPLOYEES THEMSELVES FAILED TO COMPLY WITH OPPENHEIMER'S POLICIES BY COMMUNICATING USING NON-OPPENHEIMER APPROVED METHODS ON THEIR PERSONAL DEVICES ABOUT OPPENHEIMER'S BROKER-DEALER BUSINESS. OPPENHEIMER'S WIDESPREAD FAILURE TO IMPLEMENT ITS POLICIES AND PROCEDURES THAT PROHIBIT SUCH COMMUNICATIONS LED TO ITS FAILURE TO REASONABLY SUPERVISE ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. DURING THE TIME PERIOD THAT OPPENHEIMER FAILED TO MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS ITS EMPLOYEES SENT AND RECEIVED RELATED TO THE BROKER-DEALER BUSINESS, OPPENHEIMER RECEIVED AND RESPONDED TO COMMISSION SUBPOENAS FOR DOCUMENTS AND RECORDS REQUESTS IN NUMEROUS COMMISSION INVESTIGATIONS. AS A RESULT, OPPENHEIMER RECORDKEEPING FAILURES LIKELY IMPACTED THE COMMISSION'S ABILITY TO CARRY OUT ITS REGULATORY FUNCTIONS AND INVESTIGATE VIOLATIONS OF THE FEDERAL SECURITIES LAWS ACROSS THESE INVESTIGATIONS. COMMISSION STAFF UNCOVERED OPPENHEIMER'S MISCONDUCT AFTER COMMENCING A RISK-BASED INITIATIVE TO INVESTIGATE THE USE OF OFF-CHANNEL AND UNPRESERVED COMMUNICATIONS AT BROKER-DEALERS. OPPENHEIMER HAS INITIATED A REVIEW OF ITS RECORDKEEPING FAILURES AND BEGUN A PROGRAM OF REMEDIATION. AS SET FORTH IN THE UNDERTAKINGS BELOW, OPPENHEIMER WILL RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO REVIEW AND ASSESS OPPENHEIMER'S REMEDIAL STEPS RELATING TO ITS RECORDKEEPING PRACTICES, POLICIES AND PROCEDURES, RELATED SUPERVISORY PRACTICES, AND EMPLOYMENT ACTIONS. AS A RESULT, OPPENHEIMER WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER. Status: Final Sanction Detail: THE FIRM IS ORDERED TO CEASE AND DESIST, IS CENSURED, SHALL COMPLY WITH UNDERTAKINGS ENUMERATED IN THE ORDER, AND SHALL PAY A CIVIL PENALTY OF $12,000,000. Summary: OPPENHEIMER WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, IS CENSURED, SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER AND SHALL PAY A CIVIL PENALTY OF $12,000,000.
Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST 2019 TO THE PRESENT ("RELEVANT PERIOD"), OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR "RESPONDENT") VIOLATED, AS SET FORTH BELOW, SECTION 4G OF THE COMMODITY EXCHANGE ACT ("ACT"), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 1.35, AND 166.3. THEREFORE, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED TO DETERMINE WHETHER RESPONDENT ENGAGED IN THE VIOLATIONS SET FORTH HEREIN AND TO DETERMINE WHETHER ANY ORDER SHOULD BE ISSUED IMPOSING REMEDIAL SANCTIONS. IN ANTICIPATION OF THE INSTITUTION OF AN ADMINISTRATIVE PROCEEDING, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. THE COMMISSION FINDS THAT OPPENHEIMER EMPLOYEES, INCLUDING THOSE AT SENIOR LEVELS, COMMUNICATED BOTH INTERNALLY AND EXTERNALLY USING UNAPPROVED METHODS, INCLUDING VIA PERSONAL TEXT MESSAGES AND, IN THE CASE OF AT LEAST ONE EMPLOYEE, WHATSAPP MESSAGES. THESE WRITTEN COMMUNICATIONS WERE SENT AND RECEIVED BY OPPENHEIMER EMPLOYEES AND INCLUDED MESSAGES RELATED TO OPPENHEIMER'S BUSINESS AS A COMMISSION REGISTRANT THAT WERE REQUIRED TO BE MAINTAINED UNDER COMMISSION-MANDATED RECORDKEEPING REQUIREMENTS. THESE WRITTEN COMMUNICATIONS VIA UNAPPROVED METHODS GENERALLY WERE NOT MAINTAINED AND PRESERVED BY OPPENHEIMER, AND OPPENHEIMER GENERALLY WOULD NOT HAVE BEEN ABLE TO FURNISH THE COMMUNICATIONS PROMPTLY TO A COMMISSION REPRESENTATIVE IF AND WHEN REQUESTED. AS A RESULT, OPPENHEIMER VIOLATED, AS SET FORTH BELOW, SECTION 4G OF THE ACT, AND REGULATIONS 1.31 AND 1.35. IN ADDITION, THE USE OF UNAUTHORIZED COMMUNICATION METHODS BY OPPENHEIMER EMPLOYEES TO CONDUCT FIRM BUSINESS VIOLATED OPPENHEIMER'S OWN POLICIES AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS. OPPENHEIMER DID NOT MAINTAIN ADEQUATE INTERNAL CONTROLS WITH RESPECT TO THE USE OF UNAPPROVED COMMUNICATION METHODS FOR BUSINESS-RELATED COMMUNICATIONS. INDEED, SOME OF THE VERY SAME SUPERVISORY PERSONNEL AT OPPENHEIMER RESPONSIBLE FOR ENSURING COMPLIANCE WITH OPPENHEIMER'S POLICIES AND PROCEDURES THEMSELVES UTILIZED UNAPPROVED METHODS OF COMMUNICATION TO ENGAGE IN BUSINESS-RELATED COMMUNICATIONS, IN VIOLATION OF FIRM POLICY. BECAUSE OPPENHEIMER FAILED TO IMPLEMENT A DILIGENT SUPERVISORY SYSTEM TO ENSURE COMPLIANCE WITH COMMISSION RECORDKEEPING REQUIREMENTS AND THE FIRM'S OWN POLICIES AND PROCEDURES, AND BECAUSE THE USE OF UNAUTHORIZED COMMUNICATION METHODS RESULTED IN THE FIRM'S FAILURE TO MAINTAIN COMMISSION-REQUIRED RECORDS, OPPENHEIMER FAILED TO DILIGENTLY SUPERVISE MATTERS RELATED TO ITS BUSINESS AS A COMMISSION REGISTRANT IN VIOLATION OF REGULATION 166.3. Status: Final Sanction Detail: THE FIRM IS ORDERED TO CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT, AND REGULATIONS 1.31, 1.35, AND 166.3, IS FINED $1,000,000, AND HALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN THE OFFER. Summary: ACCORDINGLY, IT IS HEREBY ORDERED THAT OPPENHEIMER AND ITS SUCCESSORS AND ASSIGNS SHALL CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT, AND REGULATIONS 1.31, 1.35, AND 166.3, IS FINED $1,000,000, AND RESPONDENT AND ITS SUCCESSORS AND ASSIGNS SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN THE OFFER.
Disclosure text reproduced verbatim from the firm's own Form ADV filings.
How they charge
- • Percentage of assets under management
- • Fixed fees
- • Commissions
Services
- • Financial planning services
- • Portfolio management for individuals/small businesses
- • Portfolio management for businesses/institutional clients
- • Pension consulting services
- • Selection of other advisers
Custody
Reported custodians
- Oppenheimer & Co. Inc. $26.3B (72% of AUM) Jun 2026
Amounts as reported in ADV Item 5.K.(3) (custodians holding 10%+ of SMA assets).
Firm reports having custody of client funds or securities (Item 9.A).
Source
All data on this page comes from this firm's Form ADV filings, reproduced without modification. Latest filing: Jun 23, 2026.
View current Form ADV (SEC/IAPD) ↗